United States Tenth Circuit
ST. CHARLES INV. CO. v. COMM'R OF INTERNAL REVENUE, 99-9020
Section 469(b) of the tax code, which allows taxpayers to deduct normally non-deductible passive activity losses in the following year, precludes application of section 1371(b)(1) of the tax code, which prohibits an S corporation from carrying over losses when it was a C corporation.
Appellate Information
- Decided 11/14/2000
- Published 11/14/2000
Judges
- TACHA, Circuit Judge., Before TACHA, McWILLIAMS, and MURPHY, Circuit Judges.
Court
- United States Tenth Circuit
Counsel
- For Appellant:
- Darrell D. Hallett (John M. Colvin, with him on the briefs), Chicoine & Hallett, P.S., Seattle, Washington, for Petitioners-Appellants.
- For Appellees:
- Ellen Page DelSole (Gilbert S. Rothenberg, with her on the brief), Attorneys, Tax Division, Department of Justice, Washington, D.C., for Respondent-Appellee.