United States Eleventh Circuit

In case where one S corporation transferred money to two other S corporations, and shareholder of the latter two claimed such transfers were bona fide loans and that the loans were effectively discharged, thereby cancelling the indebtedness income to the latter two, summary judgment in favor of government is affirmed as plaintiff shareholder failed to show the existence of a debt.

Appellate Information

• Decided 11/28/2006
• Published 11/28/2006

Judges

• BIRCH, Circuit Judge:, Before BIRCH, PRYOR and FAY, Circuit Judges.

Court

• United States Eleventh Circuit

Counsel

• For Appellant:
  
• Robert H. Hishon, The Hishon Firm, LLC, Atlanta, GA, for Plaintiffs-Appellants., Richard Farber, Annette M. Wietecha, U.S. Dept. of Justice, Tax Div., Washington, DC, for U.S.