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.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s