Legal Opinion
Michael Friedman v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 8, 2000No. 98-2378PublishedCited by 38 opinions
1Opinion of the Court
OPINION
NUGENT, District Judge.
The Commissioner of Internal Revenue (hereinafter “Commissioner”) issued notices of tax deficiencies to Michael and Madeline Friedman and Edward and Deborah Rosenthal 1 (hereinafter “Taxpayers”) for the years 1989 and 1990. The notices stated that Taxpayers were not entitled to a loss in the amount of $5,055,116. As shareholders of an S corporation, Taxpayers made claims for net operating losses of their S corporation, New Manchester, by using the corporation’s 1992 discharge of indebtedness income (a.k.a. “COD income”) to increase their stock basis, and then in…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Achiro v. CommissionerUnited States Tax Court · 1981
- Brountas v. CommissionerUnited States Tax Court · 1979
16 more not listed; retrieve them via the Exa API.
3Cited by38 opinions
- American Rice, Inc. v. Producers Rice Mill, Inc.Court of Appeals for the Fifth Circuit · 2008
- Alt v. CommissionerCourt of Appeals for the Sixth Circuit · 2004
- Martin Alpert and Carolyn Alpert v. United StatesCourt of Appeals for the Sixth Circuit · 2007
- Walter L. Gross, Jr. And Barbara H. Gross (99-2239) Calvin C. Linnemann and Patricia G. Linnemann (99-2257) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2001
- The Limited, Inc., and Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2002
33 more not listed; retrieve them via the Exa API.