MEMORANDUM OPINION
JACOBS, Judge:
Respondent determined a $45,715 deficiency in petitioners' 1994 Federal income tax. The deficiency primarily stems from the disallowance of a net operating loss carryover due to insufficient basis in petitioners' S corporation stock.
The underlying issue for decision is whether discharge of indebtedness income excluded from an S corporation's gross income under section 108(a) passes through to the S corporation's...
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