Sensenig v. Comm'r
United States Tax Court
P-H was the sole shareholder and president of CLCL, an S corporation. CLCL provided high-risk capital to various companies, including G-L, LFP, and WSC. P-H also owned an equity interest in each of G-L, LFP, and WSC.
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P-H was the sole shareholder and president of CLCL, an S corporation. CLCL provided high-risk capital to various companies, including G-L, LFP, and WSC. P-H also owned an equity interest in each of G-L, LFP, and WSC. No loan documents were created for the advances to the three corporations; P-H did not undertake "due diligence" analysis of borrowers that a typical creditor would have undertaken; CLCL made the advances notwithstanding WSC's other superior creditors; and P-H never attempted to collect repayment of the advances. P-H claimed a bad debt deduction for CLCL on CLCL's Form 1120S,…
1Opinion of the Court
JOHN M. SENSENIG AND ALTA Z. SENSENIG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sensenig v. Comm'r
Docket No. 16254-11
United States Tax Court
T.C. Memo 2017-1; 2017 Tax Ct. Memo LEXIS 1; 113 T.C.M. (CCH) 1001;
January 3, 2017, Filed
Decision will be entered under Rule 155.
P-H was the sole shareholder and president of CLCL, an S corporation. CLCL provided high-risk capital to various companies, including G-L, LFP, and WSC. P-H also owned an equity interest in each of G-L, LFP, and WSC. No loan documents were created for the advances to the three corporations; P-H did not…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
14 more not listed; retrieve them via the Exa API.
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