Legal Opinion
Dudley B. Merkel Ladonna K. Merkel David A. Hepburn, and Nancy J. Hepburn v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 17, 1999No. 98-70420PublishedCited by 70 opinions
1Opinion of the Court
Opinion by Judge WARDLAW; Dissent by Judge O’SCANNLAIN.
*846WARDLAW, Circuit Judge:
This case calls upon us to decide the standard for determining when a contingent obligation to pay is a “liability” for purposes of determining insolvency under 26 U.S.C. § 108(d)(3).
Appellants Dudley and La Donna Merk-el and David and Nancy Hepburn (“Appellants”) appeal from the Tax Court’s decision sustaining determinations of income tax deficiency for the tax year 1991 made by the Commissioner of Internal Revenue (“Commissioner”). The Tax Court found that Appellants failed to prove that as of the measurement date…
2Cases cited30 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Sawyer v. WhitleySupreme Court of the United States · 1992
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
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3Cited by70 opinions
- In Re Korean Air Lines Co., Ltd.Court of Appeals for the Ninth Circuit · 2011
- Greene v. SavageCourt of Appeals for the Ninth Circuit · 2009
- Reswick v. Reswick (In Re Reswick)United States Bankruptcy Appellate Panel for the Ninth Circuit · 2011
- United States v. GallegosCourt of Appeals for the Ninth Circuit · 2010
- Meruelo v. CommissionerCourt of Appeals for the Ninth Circuit · 2012
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