Gleason v. Comm'r
United States Tax Court
During 1995, Ps, through P-H, became involved in a leveraged buyout transaction resulting in ownership of two S corporations, A and T, and relinquishment of an interest in another S corporation, E. By early 1996, A and T were insolvent and thereafter entered bankruptcy proceedings. Held: Ps' income and losses for 1994 and 1995 related to ownership of A, T, and E are to be adjusted consistent with this opinion.
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During 1995, Ps, through P-H, became involved in a leveraged buyout transaction resulting in ownership of two S corporations, A and T, and relinquishment of an interest in another S corporation, E. By early 1996, A and T were insolvent and thereafter entered bankruptcy proceedings. Held: Ps' income and losses for 1994 and 1995 related to ownership of A, T, and E are to be adjusted consistent with this opinion. Held, further, Ps are liable for accuracy-related penalties pursuant to sec. 6662, I.R.C., for 1994 and 1995 to the extent that underpayments remain following recomputation in…
1Opinion of the Court
THOMAS AND JANICE GLEASON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gleason v. Comm'r
No. 18377-04
United States Tax Court
T.C. Memo 2006-191; 2006 Tax Ct. Memo LEXIS 198; 92 T.C.M. (CCH) 250; RIA TM 56616;
September 11, 2006, Filed
During 1995, Ps, through P-H, became involved in a leveraged
buyout transaction resulting in ownership of two S corporations, A and T, and relinquishment of an interest in another S corporation, E. By early 1996, A and T were insolvent and thereafter entered bankruptcy proceedings.
Held: Ps' income and losses for 1994 and 1995 related to ownership of A,…
2Cases cited33 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Freytag v. CommissionerSupreme Court of the United States · 1991
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
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