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RUSSELL v. C.I.R.

Nos. 09-2306, 09-2307, 09-2310, 09-2576.

619 F.3d 908 (2010)

Donald L. RUSSELL; Evelyn Russell, Appellants, v. COMMISSIONER of INTERNAL REVENUE, Appellee. United Energy Corporation, Appellant, v. Commissioner of Internal Revenue, Appellee. Loren R. Kopseng; Dawn Kopseng, Appellants, v. Commissioner of Internal Revenue, Appellee. United Energy Corporation, Appellee, v. Commissioner of Internal Revenue, Appellant.

United States Court of Appeals, Eighth Circuit.

Filed: August 27, 2010.

Attorney(s) appearing for the Case

Jon J. Jensen , argued, Grand Forks, ND, for appellants.

Randolph Lyons Hutter , DOJ, argued, Kenneth Greene , on the brief, Washington, DC, for appellee.

Before WOLLMAN, SMITH, and COLLOTON, Circuit Judges.

[PUBLISHED]

PER CURIAM.

Donald and Evelyn Russell, and Loren and Dawn Kopseng appeal the tax court's decisions that several loans did not constitute "indebtedness of the S corporation to the shareholder" such that they could claim losses incurred by the Missouri River Royalty Corporation (MRRC). United Energy Corporation (UEC) appeals the tax court's decision that it realized gain on acquisition of the Russell ledger debt and the Kopseng ledger debt in the...

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