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MERUELO v. C.I.R.

No. 18-11909.

923 F.3d 938 (2019)

Homero F. MERUELO, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

May 6, 2019.

Attorney(s) appearing for the Case

Bruce Stephen Rogow , Tara A. Campion , Bruce S. Rogow, PA, FORT LAUDERDALE, FL, Howard Wayne Gordon , Alyssa R. Wan , Fowler White Burnett, PA, MIAMI, FL, for Petitioner-Appellant.

Anthony T. Sheehan , Teresa E. McLaughlin , Gilbert Steven Rothenberg , Chief Appellate Section Tax Division, William M. Paul , Internal Revenue Service, Acting Chief Counsel, WASHINGTON, DC, W. Robert Abramitis , MIAMI, FL, for Respondent-Appellee.

Before WILLIAM PRYOR and NEWSOM, Circuit Judges, and VRATIL, District Judge.

This appeal from the disallowance of a taxpayer's claimed deduction for his share of losses suffered by an S corporation presents the following issue: whether monetary transfers between various business entities partly owned by the taxpayer and an S corporation that were later...

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