William H. Perry and Marian E. Perry 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.

• corporate debts guaranteed by the shareholder were not debt whose basis is taken into account for loss passthrough purposes
• predated notes insufficient to prove indebtedness from an S corporation to the taxpayer shareholder
• there is nothing in the statutory wording, nor the regulations, nor the committee reports which warrants an inference that a shareholder’s contract of guaranty with corporate creditors is tantamount to an indebtedness of the corporation to the shareholder
• there is nothing in the statutory wording, nor the regulations, nor the committee reports which warrants an inference that a shareholder's contract of guaranty with corporate creditors is tantamount to an indebtedness of the corporation to the shareholder
• there is nothing in the statutory wording, nor the regulations, nor the committee reports which warrants an inference that a shareholder's contract of guaranty with corporate creditors is tantamount to an indebtedness of the corporation to the shareholder

Source: CourtListener parenthetical corpus (CC0).