Legal Opinion

Shaw v. Commissioner

Court of Appeals for the Ninth Circuit

Decided November 25, 2015No. 13-73687UnpublishedCited by 2 opinions

1Opinion of the Court

MEMORANDUM ***

June Shaw appeals the Tax Court’s determination that she had a deficiency in her 2009 tax return. .We review de novo the Tax Court’s legal conclusions and review for clear error its factual findings. Johanson v. Comm’r, 541 F.3d 973, 976 (9th Cir.2008).

In 2009, June Shaw advanced $808,475 to SRG Corporation, her family’s company. SRG began facing financial difficulties and Kenneth Shaw, June’s brother and president of SRG, informed June that SRG could not repay her. Shaw listed the $808,475 as bad debt on her tax returns. The IRS denied her loss deduction and issued a deficiency…

2Cases cited3 opinions

  1. Dudley B. Merkel Ladonna K. Merkel David A. Hepburn, and Nancy J. Hepburn v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
  2. Mary Ruark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
  3. Johanson v. CommissionerCourt of Appeals for the Ninth Circuit · 2008

3Cited by2 opinions

  1. Rutter v. Comm'rUnited States Tax Court · 2017
  2. Sensenig v. Comm'rUnited States Tax Court · 2017

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