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GROJEAN v. C.I.R.

No. 00-2252.

248 F.3d 572 (2001)

Thomas F. GROJEAN and Therese Grojean, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided April 13, 2001.

Attorney(s) appearing for the Case

Edward R. Hannon (argued), Pedersen & Houpt, Chicago, IL, for Petitioners-Appellants.

Donald J. Tobin (argued), Teresa McLaughlin, Dept. of Justice, Tax Div., Appellate Section, Washington, DC, for Respondent-Appellee.

Before POSNER, DIANE P. WOOD, and WILLIAMS, Circuit Judges.

POSNER, Circuit Judge.

The question presented by this appeal is whether the Tax Court committed a clear error in characterizing Thomas Grojean's participation interest in a loan made by American National Bank to Grojean's Subchapter S corporation, Schanno Acquisition, Inc., as a guaranty.

Grojean had formed Schanno Acquisition in order to buy a trucking company from Transamerica Leasing Corporation. The price was a shade under $14 million. To finance the purchase...

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