Kauffman

"This case comes before the court, without oral argument, on plaintiffs motion for partial summary judgment. Plaintiff Ewing M. Kauffman (taxpayer) is the sole shareholder of the Kansas City Royals Baseball Corporation. For the fiscal year ended October 31, 1971, the corporation elected Subchapter S treatment pursuant to section 1372 of the Code. Taxpayer was thus entitled to deduct the corporation’s net operating loss for 1971 on his personal income tax return for that year. I.R.C. § 1374. The source of present controversy involves the allocation of the costs of forming the corporation in…