Broz v. Commissioner

OPINION

ROGERS, Circuit Judge.

Robert and Kimberly Broz appeal the judgment of the United States Tax Court affirming the Commissioner of Internal Revenue’s finding of an $18 million deficiency in their joint tax filings for the years 1996, 1998, 1999, 2000, and 2001. Robert Broz claims that he was “at risk” and had sufficient debt basis in Alpine PCS, a subchapter S corporation, to deduct its pass-through losses. Broz also argues that he made valid business-expense and amortization deductions for the activities of the Alpine license-holding entities, which were limited-liability companies taxed…