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Gitlitz Vs. Commissioner
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- US Supreme Court
- Jan 09, 2001
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U.S. 206 (2001) October Term, 2000 Syllabus Gitlitz Et Al. V. CommissionerSearch
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taxation system under which income is subjected to only one level of taxation. See Bufferd v. CommissionerSearch
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and therefore could support a basis increase. See Winn v. CommissionerSearch
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RIA Memo TC. In light of the Tax Court's decision in Nelson v. Commis-Search
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may not use an S corporation's untaxed discharge of indebtedness to increase their bases in corporate stock. See Winn v. CommissionerSearch
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of Appeals have disagreed on how to treat discharge of indebtedness of an insolvent S corporation, compare Gaudiano v. CommissionerSearch
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Witzel v. CommissionerSearch
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and 182 F. 3d, at 1150 (case below), with United States v. FarleySearch
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see also Pugh v. CommissionerSearch
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of an insolvent taxpayer was not taxable income. See, e. g., Dallas Transfer & Terminal Warehouse Co. v. CommissionerSearch
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Astoria Marine Construction Co. v. CommissionerSearch
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the discharged debt amount would reduce the net operating loss but would not be absorbed by it. Witzel v. CommissionerSearch
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an otherwise unavailable deduction, 222 thereby sheltering other, unrelated income from tax. See Witzel v. CommissionerSearch
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admits either interpretation, we should ignore the policy consequences. See Commissioner v. GilletteSearch
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U. S. 62 , 68 (1934)). See United States v. SkellySearch
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Syllabus Gitlitz Et Al. V. CommissionerSearch
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See Bufferd v. CommissionerSearch
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See Winn v. CommissionerSearch
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Nelson v. Commis-Search
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Gaudiano v. CommissionerSearch
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United States v. FarleySearch
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Pugh v. CommissionerSearch
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Dallas Transfer & Terminal Warehouse Co. v. CommissionerSearch
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See Witzel v. CommissionerSearch
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See Commissioner v. GilletteSearch
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See United States v. SkellySearch
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