Rendall v. Commissioner
Court of Appeals for the Tenth Circuit
1Opinion of the Court
TACHA, Circuit Judge.
John S. Rendall and his wife, Christobel D. Rendall, appeal from a decision of the United States Tax Court assessing a $259,874 deficiency in the Rendalls’ income tax for the taxable year 1997. The decision was based on the Tax Court’s determination that gains from the sale of stock pledged as collateral for a loan are taxable to the Rendalls and must be calculated under the first-in/first-out (“FIFO”) method, see 26 C.F.R. § 1.1012-l(c), and that the Rendalls are not entitled to a $2 million worthless-debt deduction, see 26 U.S.C. § 166(a). We have jurisdiction under 26…
2Cases cited11 opinions
- Pauly v. State Loan & Trust Co.Supreme Court of the United States · 1897
- Dustin v. CommissionerUnited States Tax Court · 1969
- Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
- Fed. Sec. L. Rep. P 96,609 National Bank of Commerce of Dallas v. All American Assurance CompanyCourt of Appeals for the Fifth Circuit · 1978
- Estate of Guy L. Mann, Deceased. Suzanne Mann Duval, Administratrix v. United StatesCourt of Appeals for the Fifth Circuit · 1984
6 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
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- In Re Pt-1 Communications, Inc.United States Bankruptcy Court, E.D. New York · 2011
- Cooper v. Comm'rUnited States Tax Court · 2014
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