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PUGH v. C.I.R.

No. 99-12646.

213 F.3d 1324 (2000)

James H. PUGH, Jr. and Alexis Pugh, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eleventh Circuit.

June 5, 2000.

Attorney(s) appearing for the Case

Charles H. Egerton, Dean, Mead, Egerton, Bloodworth, Capouano & Bozarth, P.A., Jane Dunlap Callahan, Orlando, FL, for Petitioners.

Paula K. Speck, Teresa A. McLaughlin, Tax Div., Dept. of Justice, Washington, DC, for Respondent.

Before CARNES, BARKETT and WILSON, Circuit Judges.

WILSON, Circuit Judge:

This case features a taxpayer who seeks to take personal tax advantage from his S corporation's insolvency. Put simply, the taxpayer owned shares in an S corporation. The corporation owed money, was forgiven the debt, and then liquidated. The taxpayer sought to have the cancellation-of-debt (COD) income flow through to him and increase his basis in his S corporation stock. Then the taxpayer claimed...

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