Legal Opinion
In Re Landbank Equity Corporation, a Virginia Corporation, Debtor. Internal Revenue Service v. Laurence H. Levy, Trustee, Debera F. Conlon
Court of Appeals for the Fourth Circuit
Decided October 27, 1992No. 91-1780PublishedCited by 56 opinions
1Opinion of the Court
OPINION
NIEMEYER, Circuit Judge:
In this appeal we are asked to decide whether the fact that a dispute over a tax deduction for bad debt losses under 26 U.S.C. § 166 arises in the context of a bankruptcy proceeding reverses the long-established requirement that the taxpayer bears a burden of proving that the debt became worthless in the particular year in which the deduction was taken. See Belser v. Commissioner, 174 F.2d 386, 389 (4th Cir.), cert. denied, 338 U.S. 893, 70 S.Ct. 240, 94 L.Ed. 549 (1949). Because we conclude that Congress, by merely providing for the consideration of tax claims…
2Cases cited22 opinions
- Northern Pipeline Construction Co. v. Marathon Pipe Line Co.Supreme Court of the United States · 1982
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Norwest Bank Worthington v. AhlersSupreme Court of the United States · 1988
- Immigration & Naturalization Service v. PangilinanSupreme Court of the United States · 1988
- Nicholas v. United StatesSupreme Court of the United States · 1966
17 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Raleigh v. Illinois Department of RevenueSupreme Court of the United States · 2000
- In Re Official Committee of Unsecured Creditors for Dornier Aviation (North America), Incorporated Fairchild Dornier Gmbh, Debtors. Fairchild Dornier Gmbh Doctor Eberhard Braun, Debtors-Appellants v. The Official Committee of Unsecured Creditors (The Plan Monitoring Committee), Creditor-AppelleeCourt of Appeals for the Fourth Circuit · 2006
- In the Matter of Herbert P. Carlson and Margaret P. Carlson, Debtors. Herbert P. Carlson and Margaret P. Carlson v. United StatesCourt of Appeals for the Seventh Circuit · 1997
- In Re: William Stoecker, DebtorCourt of Appeals for the Seventh Circuit · 1999
- In Re WhiteUnited States Bankruptcy Court, D. Connecticut · 1994
51 more not listed; retrieve them via the Exa API.