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BROWN v. COMMISSIONER

Docket No. 7139-77.

38 T.C.M. 886 (1979)

T.C. Memo. 1979-220

J.W. Brown and Shirley Brown v. Commissioner.

United States Tax Court.

June 4, 1979.

Attorney(s) appearing for the Case

Robert S. Brown, for the petitioners. Rudolf L. Jansen, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency of $13,826 in petitioners' Federal income taxes for the taxable year 1974.

The question for decision is whether a loan made to a Subchapter S corporation by a bank, payment of which was guaranteed by its principal stockholder, increased the stockholder's basis for the deduction of his pro rata share of the net operating losses of the corporation.

Findings...

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