Legal Opinion
Uri v. Commissioner
Court of Appeals for the Tenth Circuit
Decided November 18, 1991No. Nos. 89-9014, 89-9015PublishedCited by 18 opinions
1Opinion of the Court
HOLLOWAY, Circuit Judge.
The issue in these consolidated appeals is whether a shareholder in a subchapter S corporation who personally guarantees a bank loan to the corporation may increase his or her adjusted basis in the corporation’s stock by the prorated amount of the guarantee in order to increase the available loss deduction under the applicable version of I.R.C. § 1374. In the cases before us, the Tax Court approved the Commissioner’s disallowance of petitioners’ enhanced loss deductions. Guided by a recent Tenth Circuit opinion concerning this controlling issue, we affirm.
*372The issue…
2Cases cited9 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Estate of Leavitt v. CommissionerUnited States Tax Court · 1988
- Edward M. Selfe and Jane B. Selfe v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
- Frederick G. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1983
- Mary Ann Heyen, of the Estate of Jennie Owen, Deceased v. United StatesCourt of Appeals for the Tenth Circuit · 1991
4 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Hitchins v. CommissionerUnited States Tax Court · 1994
- Rebecca Jo Reser v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1997
- Larry Bergman Patricia Bergman v. United StatesCourt of Appeals for the Eighth Circuit · 1999
- McCoy Enterprises, Inc., & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995
- Nelson v. CommissionerUnited States Tax Court · 1998
13 more not listed; retrieve them via the Exa API.