Nathel v. Comm'r
United States Tax Court
In calculating ordinary income relating to $ 1,622,050 in loan payments received from two S corporations, for purposes of sec. 1366(a)(1), I.R.C., petitioners treated $ 1,437,248 in capital contributions they made to the S corporations as income to the S corporations and as restoring or increasing under sec. 1367(b)(2)(B), I.R.C., their tax bases in loans petitioners previously had made to the S corporations.
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In calculating ordinary income relating to $ 1,622,050 in loan payments received from two S corporations, for purposes of sec. 1366(a)(1), I.R.C., petitioners treated $ 1,437,248 in capital contributions they made to the S corporations as income to the S corporations and as restoring or increasing under sec. 1367(b)(2)(B), I.R.C., their tax bases in loans petitioners previously had made to the S corporations. Petitioners then used the restored or increased tax bases in the loans they made to the S corporations to offset ordinary income that otherwise would have been reportable by petitioners…
1Opinion of the Court
IRA NATHEL AND TRACY NATHEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent SHELDON NATHEL AND ANN M. NATHEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Nathel v. Comm'r
Nos. 17203-06, 17204-06
United States Tax Court
131 T.C. 262; 2008 U.S. Tax Ct. LEXIS 37; 131 T.C. No. 17;
December 17, 2008, Decided
In calculating ordinary income relating to $ 1,622,050 in loan payments received from two S corporations, for purposes of sec. 1366(a)(1), I.R.C., petitioners treated $ 1,437,248 in capital contributions they made to the S corporations as income to the S corporations and…
2Cases cited18 opinions
- Edwards v. Cuba RailroadSupreme Court of the United States · 1925
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Dixie Dairies Corp. v. CommissionerUnited States Tax Court · 1980
- Gitlitz v. CommissionerSupreme Court of the United States · 2001
- Rushing v. CommissionerUnited States Tax Court · 1972
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