Prashker v. Commissioner
United States Tax Court
Petitioner, the executrix and sole beneficiary of H's estate, created a subch. S corporation. Petitioner and her son were the only shareholders, each having stock with a basis of $ 5,000. The corporation incurred substantial losses during its first years of operation. The estate made numerous loans to the corporation over a period of time.
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Petitioner, the executrix and sole beneficiary of H's estate, created a subch. S corporation. Petitioner and her son were the only shareholders, each having stock with a basis of $ 5,000. The corporation incurred substantial losses during its first years of operation. The estate made numerous loans to the corporation over a period of time. Petitioner used the net operating losses of the corporation to offset her ordinary income and filed an application for tentative carryback adjustments. The net operating losses exceeded her adjusted basis in the corporation's stock. Held: (1) Petitioner is…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Taxable year Deficiency
1966 _$3,928.20
1967 _ 1, 885.06
1968 _ 6,175. 55
The disallowance by respondent of claimed net operating loss deductions and investment credits gave rise to the asserted deficiencies. Petitioner concedes the investment credits. Two issues remain for our decision: (1) Whether the petitioner is entitled to net operating loss deductions in excess of her adjusted basis in the stock of Jamy, Inc., a subchapter S corporation; and (2) whether Jamy, Inc., is indebted to the…
2Cases cited8 opinions
- Perry v. CommissionerUnited States Tax Court · 1966
- William H. Perry and Marian E. Perry v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
- Herbert's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- John E. Byrne v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1966
- Byrne v. CommissionerUnited States Tax Court · 1965
3 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Hitchins v. CommissionerUnited States Tax Court · 1994
- Blum v. CommissionerUnited States Tax Court · 1972
- Frederick G. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1983
- Frankel v. CommissionerUnited States Tax Court · 1973
- Larry Bergman Patricia Bergman v. United StatesCourt of Appeals for the Eighth Circuit · 1999
24 more not listed; retrieve them via the Exa API.