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EBERLE v. COMMISSIONER

Docket No. 10218-98.

78 T.C.M. 366 (1999)

T.C. Memo. 1999-287

Robert E. Eberle and Deborah M. Eberle v. Commissioner.

United States Tax Court.

Filed August 30, 1999.

Attorney(s) appearing for the Case

James M. Kamman, for the petitioners. Jeffrey A. Schlei and Michael H. Salama, for the respondent.

MEMORANDUM OPINION

FOLEY, Judge:

By notice dated March 30, 1998, respondent determined deficiencies in, and penalties relating to, petitioners' 1993, 1994, and 1995 Federal income taxes. After concessions, the sole issue for decision is whether discharge of indebtedness income that is excluded, pursuant to section 108, from the gross income of an S corporation increases the basis of Mr. Eberle's stock in the S...

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