Neil L. Whitesell & Tracy L. Whitesell v. Commissioner

T.C. Memo. 2019-126

UNITED STATES TAX COURT NEIL L. WHITESELL AND TRACY L. WHITESELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26230-15. Filed September 24, 2019. P-H owned a 100% interest in WIC, an S corporation. In 2008, a Michigan trial court entered a civil monetary judgment against WIC. For tax years 2008, 2009, and 2010, R allowed WIC $10,982,856 in deductions for the judgment and interest thereon. In 2011, the Michigan Court of Appeals reversed the trial court and remanded the case. In 2015, R determined deficiencies for 2010 and 2011. The deficiency for…