Legal Opinion
Estate of Leavitt v. Commissioner
Court of Appeals for the Fourth Circuit
Decided May 19, 1989No. 88-3129PublishedCited by 36 opinions
1Opinion of the Court
MURNAGHAN, Circuit Judge:
The appellants, Anthony D. and Marjorie F. Cuzzocrea and the Estate of Daniel Leavitt, Deceased, et al., appeal the Tax *421Court’s decision holding them liable for tax deficiencies for the tax years 1979, 1980 and 1981. Finding the appellants’ arguments unpersuasive, we affirm the Tax Court.
I
As shareholders of VAFLA Corporation,1 a subchapter S corporation during the years at issue, the appellants claimed deductions2 under § 1374 of the Internal Revenue Code of 19543 to reflect the corporation’s operating losses during the three years in question.4 The Commissioner…
2Cases cited16 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Estate of Leavitt v. CommissionerUnited States Tax Court · 1988
11 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Rebecca Jo Reser v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1997
- J.H. Harris, and William J. Martin v. United StatesCourt of Appeals for the Fifth Circuit · 1990
- Bolding v. CommissionerCourt of Appeals for the Fifth Circuit · 1997
- Homer Z. Goatcher, and Margaret E. Goatcher, Husband and Wife v. United StatesCourt of Appeals for the Tenth Circuit · 1991
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
31 more not listed; retrieve them via the Exa API.