Legal Opinion
Frederick Todd, II v. CIR
Court of Appeals for the Fifth Circuit
Decided August 16, 2012No. 11-60845UnpublishedCited by 8 opinions
1Opinion of the Court
PER CURIAM: *
Petitioners-Appellants Frederick and Linda Todd appeal the decision of the United States Tax Court that a purported $400,000 loan to Frederick was taxable income (and not a loan) and therefore found the Todds liable for both income tax deficiency and a penalty under I.R.C. § 6662(a). Because the Tax Court did not clearly error in finding that the purported $400,000 loan was income nor in finding that the Todds had failed to prove their affirmative defense to the penalty, we AFFIRM.
I. FACTUAL AND PROCEDURAL BACKGROUND
Frederick Todd is the sole shareholder, director, and president…
2Cases cited14 opinions
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Ernest J. Saviano and Margaret Saviano v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
- Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
- Laurie W. Tomlinson, District Director of Internal Revenue for the District of Florida v. The 1661 CorporationCourt of Appeals for the Fifth Circuit · 1967
- Green v. CommissionerCourt of Appeals for the Fifth Circuit · 2007
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3Cited by8 opinions
- United States v. William BeaversCourt of Appeals for the Seventh Circuit · 2014
- Sun v. CommissionerCourt of Appeals for the Fifth Circuit · 2018
- DF Systems, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 2013
- Minchem Int'l v. Comm'rUnited States Tax Court · 2015
- DFSystems, Incorporated v. CIRCourt of Appeals for the Fifth Circuit · 2013
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