Kligfeld Holdings, Kligfeld Corporation, Tax Matters Partner - Page 2

                                        - 2 -                                         

               Daniel J. Leer, for petitioner.                                        
               John A. Guarnieri, Meso T. Hammoud, and S. Katy Lin, for               


               HOLMES, Judge:  Marnin Kligfeld contributed a large block of           
          Inktomi Corp. stock to a partnership in 1999.  The stock was                
          shuttled from one partnership to another, theoretically gaining a           
          greatly increased basis along the way.  Most of this stock was              
          sold in 1999.  In 2000, the second partnership distributed the              
          remaining stock with its allegedly increased basis along with the           
          cash proceeds from the 1999 sale.  Kligfeld sold the leftover               
          stock and reported the sale on his 2000 joint return.1  The                 
          Commissioner challenges the amount of capital gains Kligfeld and            
          Estrin reported on their joint return, but does so by attacking             
          their reported basis.  To do this, he issued a notice of final              
          partnership administrative adjustment (FPAA) which adjusted items           
          on a 1999 partnership return.  The problem is that by the time              

               1 Kligfeld and his wife, Margo Estrin, are both parties in a           
          separate, but related, petition before this court regarding their           
          2000 tax return.  Estrin is included in that petition and is                
          mentioned in this opinion only because she and Kligfeld filed               
          jointly.  Although she and two other family members together                
          owned one percent of Kligfeld Holdings in 2000, Kligfeld is the             
          sole shareholder for Kligfeld Corporation, the tax matters                  
          partner in this case, and he and Kligfeld Corporation were the              
          only partners in Kligfeld Holdings during the 1999 taxable year.            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: November 10, 2007