Legal Opinion
Nathel v. Commissioner
Court of Appeals for the Second Circuit
Decided June 2, 2010No. Docket 09-1955-agPublishedCited by 15 opinions
1Opinion of the Court
JOHN G. KOELTL, District Judge:
The petitioners, Ira and Tracy Nathel and Sheldon and Ann M. Nathel, appeal a decision of the United States Tax Court (Stephen J. Swift, Judge) upholding tax deficiencies assessed by the Commissioner of Internal Revenue (the “Commissioner”). On appeal, the petitioners argue that certain capital contributions they made to two S corporations, of which they were shareholders, should be treated as items of “tax-exempt income” to the corporations for the purpose of restoring, pursuant to 26 U.S.C. § 1367(b)(2)(B), the petitioners’ previously reduced bases in loans…
2Cases cited38 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Christensen v. Harris CountySupreme Court of the United States · 2000
- Helvering v. CliffordSupreme Court of the United States · 1940
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3Cited by15 opinions
- Pryor v. Tiffen (In re TC Liquidations LLC)United States Bankruptcy Court, E.D. New York · 2011
- Lopez v. TerrellCourt of Appeals for the Second Circuit · 2011
- Exxon Mobil Corp. & Affiliated Cos. v. CommissionerCourt of Appeals for the Second Circuit · 2012
- AmBase Corp. v. United StatesCourt of Appeals for the Second Circuit · 2013
- Ball v. Comm'rUnited States Tax Court · 2013
10 more not listed; retrieve them via the Exa API.