Russell v. Commissioner

Donald and Evelyn Russell, and Loren and Dawn Kopseng appeal the tax court’s decisions that several loans did not constitute “indebtedness of the S corporation to the shareholder” such that they could claim losses incurred by the Missouri River Royalty Corporation (MRRC). United Energy Corporation (UEC) appeals the tax court’s decision that it realized gain on acquisition of the Russell ledger debt and the Kopseng ledger debt in the following described transaction effected pursuant to § 351 of the Internal Revenue Code. 1 See Russell v. Comm’r, T.C. Memo 2009-29, 2009 WL 306416 (2009),…