Legal Opinion
Sheldon G. Adelson and Sandra Adelson v. The United States
Court of Appeals for the Federal Circuit
Decided June 28, 1984No. Appeal 83-1300PublishedCited by 13 opinions
1Opinion of the Court
BENNETT, Circuit Judge.
The government appeals from a judgment of the United States Claims Court (Spector, J.) holding that Sheldon G. Adelson (taxpayer) 1 is entitled to a refund of $163,506.16, plus interest, based on what the court determined was a reasonable addition to a bad debt reserve under I.R.C. § 166(c) (1982). In its initial opinion, the court held that taxpayer’s advances to seven client-companies were bona fide debts, not capital contributions, and that his dominant motivation in creating the loans was to further his trade or business. 1 Cl.Ct. 61, 553 F.Supp. 1082 (1982). The…
2Cases cited7 opinions
- United States v. GeneresSupreme Court of the United States · 1972
- American Processing and Sales Company v. The United StatesUnited States Court of Claims · 1967
- Cuyuna Realty Company v. The United StatesUnited States Court of Claims · 1967
- Hambuechen v. CommissionerUnited States Tax Court · 1964
- Electronic Modules Corporation v. The United StatesCourt of Appeals for the Federal Circuit · 1982
2 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- In the Matter of Roger Roy Larson and Joan Rosemary Larson, Debtors-AppellantsCourt of Appeals for the Seventh Circuit · 1988
- Harry Litwin v. United StatesCourt of Appeals for the Tenth Circuit · 1993
- Cenex, Inc., (Formerly Known as Farmers Union Central Exchange, Inc.,) and Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 1998
- In re MarottaUnited States Bankruptcy Court, M.D. North Carolina · 2012
- Sheldon G. Adelson and Sandra Adelson v. The United StatesCourt of Appeals for the Federal Circuit · 1986
8 more not listed; retrieve them via the Exa API.