Thomas F. Grojean and Therese Grojean v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
1Opinion of the Court
POSNER, Circuit Judge.
The question presented by this appeal is whether the Tax Court committed a clear error in characterizing Thomas Grojean’s participation interest in a loan made by American National Bank to Grojean’s Sub-chapter S corporation, Schanno Acquisition, Inc., as a guaranty.
Grojean had formed Schanno Acquisition in order to buy a trucking company from Transamerica Leasing Corporation. The price was a shade under $14 million. To finance the purchase, Grojean turned to American National Bank. He asked to borrow $11 million from the bank, which was willing but insisted that he…
2Cases cited21 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Bonded Financial Services, Inc., Debtor-Appellant v. European American BankCourt of Appeals for the Seventh Circuit · 1988
- Bartels v. BirminghamSupreme Court of the United States · 1947
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