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United States Eighth Circuit


TOBERMAN v. COMM'R OF INTERNAL REVENUE, 01-1398

A taxpayer met the insolvency exception to discharge of indebtedness income, and thus was insolvent at the time of discharge of his debt to his Subchapter S corporation; disallowance of claimed net-operating-loss carryforwards, and assessment of an accuracy-related penalty, were appropriate.

Appellate Information

  • Decided 06/20/2002
  • Published 06/20/2002

Judges

  • RICHARD S. ARNOLD, Circuit Judge., BEFORE:  BOWMAN, RICHARD S. ARNOLD, and HANSEN, Circuit Judges.

Court

  • United States Eighth Circuit

Counsel

  • For Appellant:
  • Daniel W. Schermer, argued, Minneapolis, MN, for appellant.

  • For Appellees:
  • Kenneth W. Rosenberg, argued, DOJ, Washington, DC, for appellee.
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