Legal Opinion
Estate of Hoffman v. Commissioner, IRS
Court of Appeals for the Fourth Circuit
Decided May 8, 2001No. 00-1372UnpublishedCited by 1 opinion
1Opinion of the Court
OPINION
2Per curiam
Petitioners appeal the decision of the United States Tax Court finding that advances made to their closely-held corporation were non-deductible loans and that prepaid real estate taxes were not deductible in the year paid. We have jurisdiction to review the decision of the Tax Court “in the same manner and to the same extent as decisions of the district courts in civil actions tried without a jury.” Thomas v. Commissioner of Internal Revenue, 62 F.3d 97, 99 (4th Cir.1995) (citing 26 U.S.C. § 7482).
Petitioners own 80 percent of the stock of Hilltop Stud Farms, Inc. (Hilltop), a…
3Cases cited15 opinions
- Frank J. Hradesky v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
- Reading & Bates Corp. v. United StatesUnited States Court of Federal Claims · 1998
- Hyman S. Zfass v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1997
- In Re Landbank Equity Corporation, a Virginia Corporation, Debtor. Internal Revenue Service v. Laurence H. Levy, Trustee, Debera F. ConlonCourt of Appeals for the Fourth Circuit · 1992
- Paul L. Thomas v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1995
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4Cited by1 opinion
- In re MarottaUnited States Bankruptcy Court, M.D. North Carolina · 2012