United States Ninth Circuit
Sollberger v. Comm'r of Internal Revenue, 11-71883
The decision of the Tax Court, holding that petitioner owes $128,979 in income tax for the 2004 taxable year, is affirmed as the proceeds petitioner received from the transfer of floating rate notes constituted a sale for tax purposes, despite its taking the form of a loan, because the burdens and benefits of owning the notes were transferred to the lender.
Appellate Information
- Decided 08/16/2012
- Published 08/16/2012
Judges
- Smith
Court
- United States Ninth Circuit