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United States Tenth Circuit


Rendall v. Comm'r of Internal Revenue, 06-9007

A decision assessing petitioners-taxpayers a deficiency of over $250,000 in their income tax is affirmed where: 1) the district court properly determined that gains from a sale of stock pledged as collateral for a loan were taxable to plaintiffs and had to be calculated under the first-in/first-out (FIFO) method; and 2) the tax court did not clearly err in finding they were not entitled to a $2 million worthless-debt deduction.

Appellate Information

  • Decided 08/05/2008
  • Published 08/06/2008

Judges

  • TACHA, Circuit Judge., Before TACHA, BRISCOE, and HARTZ, Circuit Judges.

Court

  • United States Tenth Circuit

Counsel

  • For Appellant:
  • Charles E. Anderson, Santa Fe, NM, appearing for Appellants.

  • For Appellees:
  • Ellen Page Delsole, Attorney, Tax Division (Nathan J. Hochman, Assistant Attorney General, and Teresa E. McLaughlin, Attorney, Tax Division, with her on the brief), Department of Justice, Washington, D.C., appearing for Appellee.
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