Legal Opinion
Marcus W. Melvin and Marilyn E. Melvin v. Commissioner of Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided January 23, 1990No. 87-7377PublishedCited by 39 opinions
1Per curiam
Marcus Melvin appeals the Tax Court’s partial disallowance of a deduction for a bad partnership loan. The Tax Court held that Melvin was “at risk” for, and therefore could deduct under 26 U.S.C. § 465, only for his pro rata share of the loan. The court disallowed the deduction of the remaining portion of the loan, even though Melvin was personally liable for the entire amount, because any portion over the pro rata share was recoverable by right of contribution under California law. We affirm.
FACTS AND PROCEEDINGS
During 1979, Marcus Melvin owned a 71.4286 percent interest in Medici Film…
2Cases cited7 opinions
- Joseph R. Bolker v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Durkin v. CommissionerUnited States Tax Court · 1986
- Melvin v. CommissionerUnited States Tax Court · 1987
- Porreca v. CommissionerUnited States Tax Court · 1986
- Jerry E. Pritchett and Patricia D. Pritchett v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
2 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Casebeer v. CommissionerCourt of Appeals for the Ninth Circuit · 1990
- American Principals Leasing Corp. v. United StatesCourt of Appeals for the Ninth Circuit · 1990
- Dean B. Smith and Irma Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
- Thornock v. Comm'rUnited States Tax Court · 1990
- Young v. CommissionerCourt of Appeals for the Eleventh Circuit · 1991
34 more not listed; retrieve them via the Exa API.