Interaction of the AMT and S Corporation Basis Rules (Part II) — footnotes

¹²See Regs. Sec. 1.1366-2(a)(6) and Secs. 59(h) and 1015 for a discussion of the basis of property acquired by gift.

¹³See Regs. Sec. 1.1015-1(a)(2).

¹⁴See Secs. 422 and 56(b)(3); see also Robert J. Merlo, 126 TC 205 (2006).

¹⁵Charles C. Allen III, 118 TC 1 (2000).

¹⁶See Sec. 56(c)(2).

¹⁷See Sec. 1368(e).

¹⁸See the instructions for 2006 Form 1120S, U.S. Income Tax Return for an S Corporation, Schedule K, Shareholders’ Pro Rata Share Items, line 17c, Dividend distributions paid from accumulated earnings and profits.

¹⁹See the instructions for 2006 Form 1120S, Schedule K.

²⁰This schedule is available to AICPA Tax Section members via the AICPA website, at http://tax.aicpa.org/Resources/S+Corporations/Tools+and+
Aids. As this article went to press, Creative Solutions Ultra Tax was released, containing input areas for AMT basis schedules for partnerships and S corporations. For more information, visit www.creativesolutions.thomson.com.