University Heights at Hamilton Corp. v. Commissioner
United States Tax Court
Respondent mailed notices of FSAA's in which he determined adjustments to enumerated subchapter S items and determined that two of the three shareholders had insufficient bases to support their distributive share of subchapter S corporation losses claimed on their individual tax returns.
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Respondent mailed notices of FSAA's in which he determined adjustments to enumerated subchapter S items and determined that two of the three shareholders had insufficient bases to support their distributive share of subchapter S corporation losses claimed on their individual tax returns. Held: We have no jurisdiction to determine the amount of individual shareholders' bases, but we do have jurisdiction over those subchapter S items enumerated in the FSAA's, even though these items affect shareholders' bases.
1Opinion of the Court
OPINION
CLAPP, Judge:
This matter is before the Court on petitioner’s motion to dismiss for lack of jurisdiction filed August 22, 1990. On December 15, 1989, respondent mailed notices of final S corporation administrative adjustment (FSAA) to Paul Celler, the tax matters person (TMP) of University Heights at Hamilton Corp. (University Heights) for the taxable years ending October 31, 1984, October 31, 1985, and October 31, 1986. The explanation of items forms attached to each FSAA stated that University Heights was a “no change.” The deductions and losses of University Heights and their…
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