United States Eighth Circuit
Estate of Farnam v. Comm'r. of Int'l. Rev., 08-3196
In a taxpayer's appeal from the tax court's decision disallowing a claimed deduction, the order is affirmed where an "interest" in a corporation under I.R.C. section 2057(a) is necessarily limited to an equity or ownership interest, and does not include a creditor's "interest" in an unsecured debt owed by the corporation.
Appellate Information
- Decided 10/08/2009
- Published 10/08/2009
Judges
- LIMBAUGH, District Judge., Before SMITH and SHEPHERD, Circuit Judges, and LIMBAUGH, District Judge.
Court
- United States Eighth Circuit
Counsel
- For Appellant:
- Robert James Stuart, argued, Sue Ann Nelson, on the brief, Minneapolis, MN, for appellant.
- For Appellees:
- Christine Durney Mason, DOJ, argued, Jonathan S. Cohen, DOJ, on the brief, Washington, DC, for appellee.