he Ace Sporting Goods Store (an S corporation) is owned by Dick and Harry. Dick and Harry each own one-half of Ace’s stock and have a $2,000 basis in their respective shares. At incorporation, Dick loaned $4,000 to Ace and received a five year, 12% note from the corporation.
(a) If Ace has an $8,000 loss from business operations this year, what will be the results to Dick and Harry? Do you have any suggestions for Harry? Would it matter if on December 15 Ace borrowed $4,000 from its bank on a full recourse basis? What if Dick and Harry personally guaranteed the loan? Compare §§752(a) and 722.
(b) If Ace has $6,000 of net income from business operations next year, what will be the results to Dick and Harry?
(c) What difference would it make in (a), above, if the $8,000 loss was made up of $2,000 of losses from business operation and a $6,000 long-term capital loss? See Reg. §1.704-1(d)(2).
he Ace Sporting Goods Store (an S corporation) is owned by Dick and Harry. Dick and Harry…
he Ace Sporting Goods Store (an S corporation) is owned by Dick and Harry. Dick and Harry each own one-half of Ace's stock and have a $2,000 basis in their respective shares. At...
