BRIAN THOMAS v. STATE OF FLORIDA

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• disallowing increase in basis in S corporation, absent economic outlay or realization of income on the part of the shareholder
• \the courts have consistently required some economic outlay by the guarantor in order to convert a mere loan guaranty into an investment\
• no basis increase for shareholder-guaranteed loan to corporation; majority refused to apply debt-equity principles to S corporation's guaranteed loan, rejecting Selfe
• the existence of a contingent liability of shareholder as a guarantor also insufficient
• the existence of a contingent liability of shareholder as a guarantor also insufficient
• taxpayers are bound by the structure of their transaction

Source: CourtListener parenthetical corpus (CC0).