Legal Opinion
Edward M. Selfe and Jane B. Selfe v. United States
Court of Appeals for the Eleventh Circuit
Decided December 23, 1985No. 85-7026PublishedCited by 66 opinions
1Opinion of the Court
KRAVITCH, Circuit Judge:
This appeal requires us to determine whether a shareholder in a Subchapter S corporation, who personally guarantees and secures a corporate debt, may increase the adjusted basis of her stock by the full amount of the debt in order to maximize her loss deductions under I.R.C. section 1374. 1
The district court granted summary judgment in favor of the government and dismissed taxpayers’ suit for refund of $24,287 in federal income taxes and interest paid. The district court also denied appellants’ motion for summary judgment. We reverse and remand.
Taxpayer, Jane B. Selfe,…
2Cases cited23 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
18 more not listed; retrieve them via the Exa API.
3Cited by66 opinions
- Estate of Leavitt v. CommissionerUnited States Tax Court · 1988
- Rebecca Jo Reser v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1997
- Estate of Leavitt v. CommissionerCourt of Appeals for the Fourth Circuit · 1989
- J.H. Harris, and William J. Martin v. United StatesCourt of Appeals for the Fifth Circuit · 1990
- Larry Bergman Patricia Bergman v. United StatesCourt of Appeals for the Eighth Circuit · 1999
61 more not listed; retrieve them via the Exa API.