Frederick v. Commissioner
United States Tax Court
The sole issue for decision is whether petitioners must include in income a recovery of interest expense by an S corporation, in which they were shareholders, when the interest expense was deducted by the corporation in a prior year when it was governed by the rules of subchapter C. Held, petitioners must include this recovery in income.
1Opinion of the Court
Laro, Judge:
Theodore A. Frederick, Clare Frederick, and Arthur C. Frederick separately petitioned this Court for a redetermination of respondent’s determination of a deficiency in their respective 1986 Federal income tax liability (hereinafter, Theodore A. Frederick, Clare Frederick, and Arthur C. Frederick are collectively referred to as petitioners, and separately referred to as Theodore, Clare, and Arthur, respectively). Following a joint motion by petitioners under Rule 141(a),2 the three cases resulting from these petitions were consolidated into a single case for trial, briefing, and…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Bull v. United StatesSupreme Court of the United States · 1935
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
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3Cited by15 opinions
- Hughes & Luce, L.L.P. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Maines v. Comm'rUnited States Tax Court · 2015
- Barnes v. Comm'rUnited States Tax Court · 2012
- St. Charles Inv. Co. v. CommissionerUnited States Tax Court · 1998
- Barnes v. Comm'rUnited States Tax Court · 2016
10 more not listed; retrieve them via the Exa API.