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ROESCH v. COMMISSIONER

Docket No. 36413-85.

57 T.C.M. 64 (1989)

T.C. Memo. 1989-158

Edgar B. Roesch, Jr., and Betsy T. Roesch v. Commissioner.

United States Tax Court.

Filed April 11, 1989.

Attorney(s) appearing for the Case

Edgar B. Roesch, Jr., pro se. John C. McDougal, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

Respondent determined a deficiency of $6,067.28 in petitioners' Federal income tax for the taxable year ended December 31, 1982.

The sole issue for our determination is whether a shareholder's guarantee of the debt of an electing small business corporation under subchapter S of the Internal Revenue Code increases the shareholder's basis in his stock in the corporation.

Findings of Fact...

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