(petitioners’ S corporation restaurant business sustained losses for multiple years and didn’t deduct loss in year in which basis existed to allow deduction, but rather reported income in like amount and claimed income amount added to basis; court determined that reporting S corporation income that wasn’t actually earned does not increase basis under I.R.C. §1367; no capital contributions made in year in which stock basis increase claimed; no upward adjustment to basis for amounts incorrectly reported as pass-through income which doesn’t correspond to shareholder’s actual pro-rata share of such income; basis reduced even if shareholder does not actually claim pass-through losses on return; petitioners could not deduct NOL in year with lack of evidence showing correct computation of income/NOLs in prior years - issue first raised after trial).