MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge:
Respondent determined deficiencies in petitioner's Federal income tax by disallowing operating losses sustained by an S corporation in which petitioner was the sole shareholder. After concessions, the sole issue before the Court is whether petitioner is entitled to increase his adjusted basis in the S corporation by $4 million, the amount of a loan a third party made to the S corporation. Resolving this...
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