A majority of the Tax Court concludes that a stock loan program is a disguised sale. Judges Halpern, Wherry and Holmes, weigh in with concurring opinions.
Read the opinion here.
Calloway v. Commissioner, 135 T.C. No. 3 (2010)
Developments in Federal and State Tax Litigation
A majority of the Tax Court concludes that a stock loan program is a disguised sale. Judges Halpern, Wherry and Holmes, weigh in with concurring opinions.
Read the opinion here.
Calloway v. Commissioner, 135 T.C. No. 3 (2010)