Sensenig v. Commissioner (CA3 Jan.23, 2018): Lost Investment in Company Was Equity, Not Worthless Loan Under Code Sec. 166(a)(1)

In Sensenig v. Commissioner, the Third Circuit Court of Appeals affirmed the Tax Court and agreed with IRS characterization of transfers from a taxpayer to companies in which he had an equity interest as equity investments, not loans. Accordingly, the Court upheld the disallowance of the taxpayer’s deduction of the transfers as “wholly worthless” loans under Code Sec. 166(a)(1).

See full opinion of Sensenig v. Commissioner (CA3 Jan.23, 2018) by clicking here.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.

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