Donald G. Oren Beverly J. Oren v. Commissioner of Internal Revenue

WOLLMAN, Circuit Judge.

This appeal follows the tax court’s ruling affirming the Commissioner of Internal Revenue’s (“Commissioner”) determination of deficiencies in Donald G. and Beverly J. Oren’s (collectively “Orens”) 1993, 1994, and 1995 joint tax returns. The tax court held that because the funds Mr. Oren (“Oren”) purportedly loaned to two S corporations 1 were neither “actual economic outlays” nor “at risk,” the Orens were not entitled to the claimed deductions. We affirm.

I

The Oren family owned three S corporations that performed various functions within the family’s trucking business. 2…