news anchor/investigative reporter Kerri O'Brien attended an eight-hour shooting class that focused on important information, such as knowing the different parts of the firearms, and how to properly store, load, shoot, and even clean a pistol.
In 1999, WRIC elected to be taxed as an S corporation pursuant to Sec.
4,2003, WRIC elected to treat AIS as a QSub, resulting in a deemed liquidation of AIS.
5, 2003, the trusts and the unrelated taxpayer sold all their WRIC stock to an unrelated buyer for $230.
The IRS denied the claimed losses by disallowing the trusts' basis increase in their WRIC stock resulting from the QSub election and issued deficiency notices to the trusts resulting in a combined assessment of $33.
In Ball the trusts argued that the combined effect of these provisions was to require a basis increase in the WRIC stock upon the QSub election for AIS.
Accordingly, no item of income was first recognized by WRIC under Sec.