(DOWNLOAD) "Friedman V. Commissioner Of Internal Revenue" by Sixth Circuit U.S. Court of Appeals ~ eBook PDF Kindle ePub Free
eBook details
- Title: Friedman V. Commissioner Of Internal Revenue
- Author : Sixth Circuit U.S. Court of Appeals
- Release Date : January 08, 2000
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 79 KB
Description
The Commissioner of Internal Revenue (hereinafter "Commissioner") issued notices of tax deficiencies to Michael and Madeline Friedman and Edward and Deborah Rosenthal*fn1 (hereinafter "Taxpayers") for the years 1989 and 1990. The notices stated that Taxpayers were not entitled to a loss in the amount of $5,055,116. As shareholders of an S corporation, Taxpayers made claims for net operating losses of their S corporation, New Manchester, by using the corporation's 1992 discharge of indebtedness income (a.k.a. "COD income") to increase their stock basis, and then in turn, using the increased basis to claim net operating losses from prior years. The Commissioner denied Taxpayers' claims for net operating loss deductions, determining that COD income of an insolvent S corporation cannot be used to increase the shareholders' basis.