Legal Opinion
Sun v. Commissioner
Court of Appeals for the Fifth Circuit
Decided January 18, 2018No. 16-60270PublishedCited by 5 opinions
1Opinion of the Court
GREGG COSTA, Circuit Judge:
A friend from overseas sent Jerry Sun and a company Sun controlled about $19 million to invest. Sun used almost $6 million for personal expenses. Another $4 million was kept in the accounts of Sun’s company. The remaining $9 million or so was invested, but it was held in brokerage accounts in Sun’s name, mingled with his other funds, and the gains or losses were reported on Sun’s taxes. The tax court held a trial to determine the appropriate tax treatment of the $19 million. It considered various theories. Sun argued the money was a loan, which would mean he did not…
2Cases cited23 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- James v. United StatesSupreme Court of the United States · 1961
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Rutkin v. United StatesSupreme Court of the United States · 1952
18 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- United National Insurance Company, a Pennsylvania Corporation, and Travelers Casualty and Surety Company, Formerly Known as Aetna Casualty and Surety Company v. R&d Latex Corporation, a Georgia Corporation Royalty Carpet Mills, Inc., a California Corporation, and Mydrin, Inc., for Itself and as Successor in Interest to R&d Latex Corp., Mydrin, Inc., for Itself and as Successor in Interest to R&d Latex Corp., Plaintiff-Counter v. Travelers Casualty and Surety Company, Formerly Known as Aetna Casualty and Surety Company, Defendant-Counter-Claimant-Appellant, and William C. Morison-Knox and Michael D. ProughCourt of Appeals for the Ninth Circuit · 2001
- Ray v. CIRCourt of Appeals for the Fifth Circuit · 2021
- Fields v. CIRCourt of Appeals for the Fifth Circuit · 2026
- RB-1 Investment Partners, Eric Reinhart, Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
- Ugorji Timothy Wilson Onyeani v. CommissionerUnited States Tax Court · 2020