Legal Opinion
Ira and Tracy Nathel v. Commissioner
United States Tax Court
Decided December 17, 2008No. 17203-06, 17204-06Unknown
1Opinion of the Court
131 T.C. No. 17
UNITED STATES TAX COURT IRA NATHEL AND TRACY NATHEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent SHELDON NATHEL AND ANN M. NATHEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 17203-06, 17204-06. Filed December 17, 2008. In calculating ordinary income relating to $1,622,050 in loan payments received from two S corporations, for purposes of sec. 1366(a)(1), I.R.C., petitioners treated $1,437,248 in capital contributions they made to the S corporations as income to the S corporations and as restoring or increasing under sec.…
2Cases cited18 opinions
- Edwards v. Cuba RailroadSupreme Court of the United States · 1925
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Dixie Dairies Corp. v. CommissionerUnited States Tax Court · 1980
- Gitlitz v. CommissionerSupreme Court of the United States · 2001
- Rushing v. CommissionerUnited States Tax Court · 1972
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