KRAVITCH, Circuit Judge:
This appeal requires us to determine whether a shareholder in a Subchapter S corporation, who personally guarantees and secures a corporate debt, may increase the adjusted basis of her stock by the full amount of the debt in order to maximize her loss deductions under I.R.C. section 1374.
The district court granted summary judgment in favor of the government and dismissed taxpayers' suit for refund of...
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