Gary R. Frink, Sherry R. Frink v. Commissioner of Internal Revenue, (Two Cases). Gary R. Frink, Sherry R. Frink v. Commissioner of Internal Revenue

In this tax dispute, the taxpayers deducted their distributive share of partnership losses derived from the operation of a hotel during the years 1975-77. Record title to the hotel was held by Argo, a corporation which served as the nominal debtor at the lender’s request in order to avoid Mississippi’s limitation on interest charged to non-corporate borrowers. The Commissioner disallowed the deductions, but the Tax Court held that Argo was the partnership’s corporate agent and that the taxpayers could therefore deduct their distributive share of Argo’s losses. This court reversed that portion…