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KLEIN v. COMMISSIONER

Docket No. 630-76.

75 T.C. 298 (1980)

SAM W. KLEIN AND LA DONNA KLEIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 26, 1980.

Attorney(s) appearing for the Case

Jeffry L. Weiler, Robert C. Coplan, Martin J. Mehall, for the petitioners.

Buckley D. Sowards, William D. Brackett, and John P. Graham, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' income tax of $26,782.29 for 1972. After concessions, the sole issue to be decided is the extent to which distributions in the course of a complete liquidation of an electing subchapter S corporation reduce a shareholder/creditor's basis in the corporation for computing his net operating loss deduction limitation defined in section...

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