Legal Opinion
Salvador A. Gaudiano,et Al.,petitioners-Appellants v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided July 18, 2000No. 99-1294PublishedCited by 4 opinions
1Opinion of the Court
OPINION
NUGENT, District Judge.
The Commissioner of Internal Revenue (hereinafter the “Commissioner”) assessed tax deficiencies against Salvador A. and Kathleen M. Gaudiano, Randy C. and Kathleen R. Edgemon, Gary D. Asher, and Larry A. Asher (collectively the “Taxpayers”) for the year 1993. The Commissioner determined that the Taxpayers had improperly utilized discharge of indebtedness income to increase their bases in the stock of their Subchapter S corporation 'Four A Coal Co. 1 Each Taxpayer then used the increase in basis to deduct certain losses. The Commissioner disallowed the deductions.…
2Cases cited10 opinions
- Bose Corp. v. Consumers Union of United States, Inc.Supreme Court of the United States · 1984
- Tokarski v. CommissionerUnited States Tax Court · 1986
- In Re Scheirich CompanyCourt of Appeals for the Sixth Circuit · 1993
- Estate of Bessie I. Mueller, Deceased John S. Mueller, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1998
- Nelson v. CommissionerUnited States Tax Court · 1998
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3Cited by4 opinions
- Gitlitz v. CommissionerSupreme Court of the United States · 2001
- Michael Friedman v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
- Gitlitz v. CommissionerSupreme Court of the United States · 2001
- Posluns v. Comm'rUnited States Tax Court · 2012