Klein v. Commissioner
United States Tax Court
Petitioner Sam Klein was a creditor/shareholder of a subch. S corporation which was completely liquidated, thereby closing its taxable year, and which had a net operating loss for that year. Held, his share of the net operating loss should be taken into account before reduction of his basis in his equity and stock by the amounts distributed to him in complete liquidation on account of his creditor/ shareholder status. Abdalla v. Commissioner, 69 T.C. 697 (1978), applied.
1Opinion of the Court
Sam W. Klein and La Donna Klein, Petitioners v. Commissioner of Internal Revenue, Respondent
Klein v. Commissioner
Docket No. 630-76
United States Tax Court
75 T.C. 298; 1980 U.S. Tax Ct. LEXIS 23;
November 26, 1980, Filed
Decision will be entered under Rule 155.
Petitioner Sam Klein was a creditor/shareholder of a subch. S corporation which was completely liquidated, thereby closing its taxable year, and which had a net operating loss for that year. Held, his share of the net operating loss should be taken into account before reduction of his basis in his equity and stock by the amounts distributed…
2Cases cited11 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Fribourg Navigation Co. v. CommissionerSupreme Court of the United States · 1966
- Easson v. CommissionerUnited States Tax Court · 1960
- Jacob Abdalla and Mary T. Abdalla v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1981
- Dan E. Mason and Beverly R. Mason v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
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