United States Fifth Circuit
Ferguson v. Comm'r. of Int'l. Rev., 06-60697
The denial of Petitioners' petition to redetermine their tax amount is affirmed, where: 1) the conversion of bankruptcy proceedings during the relevant tax year did not cause Petitioners to realize any gain or loss; and 2) a loan secured by Petitioner with certain real property was a "nonbusiness debt" under I.R.C. section 166(d)(2).
Appellate Information
- Decided 05/12/2009
- Published 05/12/2009
Judges
- OWEN, Circuit Judge:, Before DeMOSS, DENNIS and OWEN, Circuit Judges.
Court
- United States Fifth Circuit
Counsel
- For Appellant:
- Searcy M. Ferguson, Jr. (argued), Dallas, TX, pro se and for Elizabeth Ferguson., Randolph Lyons Hutter (argued), Nathan J. Hochman, Andrea R. Tebbets, U.S. Dept. of Justice, Tax Div., Robert R. Di Trolio, Clerk, U.S. Tax Court, Clarissa C. Potter, IRS, Washington, DC, for CIR., Greg L. Germain, Syracuse University College of Law, Syracuse, NY, pro se Amicus Curiae.