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Taxation & Estate Planning

: TaxProf Blog

Tax Court Recharacterizes Nonrecourse Loan of Stock as Sale

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A divided Tax Court yesterday recharacterized a purported nonrecourse loan of 90% of the value of 990 IBM shares as a sale of the stock. Calloway v. Commissioner, 135 T.C. No. 3 (July 8, 2010). In a stinging concurrence, Judge Holmes stated: "The majority (admittedly at the Commissioner?s behest) instead...

Full post as published by TaxProf Blog on July 09, 2010 (boomark / email).

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