-19- Dial USA, Inc. v. Commissioner, 95 T.C. at 5 n.5. [Id. at 312; fn. ref. omitted.] We have also considered a similar issue with respect to contributions of property to a passthrough entity and the effect of the contributions on the basis of individual members. In Dial USA, Inc. v. Commissioner, 95 T.C. 1 (1990), we considered whether a member’s basis in an S corporation is a “subchapter S item” within the meaning of former section 6245.12 We acknowledged that the partnership audit and litigation provisions contained in sections 6221-6231 “were, in effect, grafted onto the subchapter S audit and litigation provisions” by former section 6244, id. at 3, and we held that a member’s basis in the passthrough entity was not an item “required” to be taken into account by the entity for the entity’s taxable year, id. at 5-6. We conclude that it is not necessary or appropriate to decide the basis and at-risk issues. To reflect the foregoing, An appropriate decision will be entered. 12The subch. S audit and litigation provisions were repealed by the Small Business Job Protection Act of 1996, Pub. L. 104- 188, sec. 1307(c)(1), 110 Stat. 1781, applicable to tax years beginning after Dec. 31, 1996.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19Last modified: November 10, 2007