In a case appealable to the Sixth Circuit Court of Appeals, the Tax Court maintains that Treas. Reg. 1.6015-5(b)(1) is an invalid interpretation of IRC 6015(f) in circuits other than the Seventh Circuit (where such a ruling was overturned in Lantz v. Commissioner).
Monthly Archives: September 2010
8th Circuit: No S Corp Basis in Non-Economic Loans
The Eighth Circuit upholds the Tax Court’s finding that S Corp. shareholders did not have basis from loans to the corporation where there was no economic outlay by the shareholder.
Russell v. Commissioner, No. 09-2306 (8th Cir., Aug. 27, 2010)