Blum v. Commissioner
United States Tax Court
The allowable portion of a net operating loss properly deductible by a shareholder in an electing small business corporation does not include corporate debts to third parties which have been guaranteed by the shareholder. The guaranteed debt was not indebtedness of the corporation to the shareholder and was not in substance a loan from the third-party lender to the shareholder followed by the shareholder's equity contribution to the corporation.
1Opinion of the Court
Peter E. Blum, Petitioner v. Commissioner of Internal Revenue, Respondent
Blum v. Commissioner
Docket No. 2738-71
United States Tax Court
59 T.C. 436; 1972 U.S. Tax Ct. LEXIS 9;
December 19, 1972, Filed
Decision will be entered under Rule 50.
The allowable portion of a net operating loss properly deductible by a shareholder in an electing small business corporation does not include corporate debts to third parties which have been guaranteed by the shareholder. The guaranteed debt was not indebtedness of the corporation to the shareholder and was not in substance a loan from the third-party lender to…
2Cases cited23 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Pollack v. CommissionerUnited States Tax Court · 1966
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