Legal Opinion
Frederick G. Brown v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided May 4, 1983No. 82-1372PublishedCited by 44 opinions
1Opinion of the Court
ORDER
Petitioners appeal the Tax Court’s decision holding them liable for tax deficiencies for the years 1970, 1971, and 1972. As shareholders in the Flint Motor Inn Company, a Subchapter S corporation, petitioners claimed deductions under § 1374 of the Internal Revenue Code to reflect the corporation’s operating losses during the three years in question. These deductions included pro rata shares of a $400,000 loan, which the corporation had obtained from the Westinghouse Credit Corporation, and which petitioners had guaranteed.
Section 1374 permits the shareholders of a corporation electing…
2Cases cited11 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Morris G. Underwood and Jackie Underwood, Individuals v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
- Raynor v. CommissionerUnited States Tax Court · 1968
- Perry v. CommissionerUnited States Tax Court · 1966
6 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Estate of Leavitt v. CommissionerUnited States Tax Court · 1988
- Edward M. Selfe and Jane B. Selfe v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
- Rebecca Jo Reser v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1997
- Estate of Leavitt v. CommissionerCourt of Appeals for the Fourth Circuit · 1989
- J.H. Harris, and William J. Martin v. United StatesCourt of Appeals for the Fifth Circuit · 1990
39 more not listed; retrieve them via the Exa API.