Legal Opinion
William H. Maloof v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided August 4, 2006No. 05-1967PublishedCited by 18 opinions
1Opinion of the Court
OPINION
SUTTON, Circuit Judge.
In filing a series of individual tax returns in the 1990s, William Maloof claimed significant deductions for losses incurred by S corporations that he owned. Under 26 U.S.C. § 1366(d)(1), Maloofs deductions from these losses could not exceed his basis in the stock or debt of the corporations. Recognizing that the losses greatly exceeded his initial investment in the corporations, Maloof claimed that a $4 million bank loan to the corporations in 1993, on which Maloof was a co-obligor and guarantor, permissibly increased his basis in debt of the S corporation to the…
2Cases cited13 opinions
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Bufferd v. CommissionerSupreme Court of the United States · 1993
- Gitlitz v. CommissionerSupreme Court of the United States · 2001
- Underwood v. CommissionerUnited States Tax Court · 1975
- Edward M. Selfe and Jane B. Selfe v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
8 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Linda Holt v. John GriffinCourt of Appeals for the Sixth Circuit · 2017
- Broz v. Comm'rUnited States Tax Court · 2011
- Broz v. CommissionerCourt of Appeals for the Sixth Circuit · 2013
- Nathel v. Comm'rUnited States Tax Court · 2008
- Garavaglia v. Comm'rUnited States Tax Court · 2011
13 more not listed; retrieve them via the Exa API.