Frederick G. Brown v. Commissioner of Internal Revenue

How courts have described this case

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

• “[T]he courts have consistently required some economic outlay by the guarantor in order to convert a mere loan guaranty into an investment.”
• “[T]he courts have consistently required some economic outlay by the guarantor in order to convert a mere loan guaranty into an investment.”
• \the courts have consistently required some economic outlay by the guarantor in order to convert a mere loan guaranty into an investment\
• \[T]he courts have consistently required some economic outlay by the guarantor in order to convert a mere loan guaranty into an investment.\
• absent an economic outlay requirement for obtaining an increase in basis, subchapter S shareholders could readily skirt the limitation embodied in section 1374(c) and thereby erect a tax shelter that Congress never intended to create
• absent an economic outlay requirement for obtaining an increase in basis, subchapter S shareholders could readily skirt the limitation embodied in section 1374(c) and thereby erect a tax shelter that Congress never intended to create

Source: CourtListener parenthetical corpus (CC0).