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  5. 131 T.C. No. 17
 

NATHEL v. COMMISSIONER OF INTERNAL REVENUE

Nos. 17203-06, 17204-06

131 T.C. No. 17

IRA NATHEL AND TRACY NATHEL, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. SHELDON NATHEL AND ANN M. NATHEL, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 17, 2007.

Attorney(s) appearing for the Case

Hugh Janow, for petitioners.

Donald A. Glasel, for respondent.

OPINION

SWIFT, Judge:

Respondent determined deficiencies in the respective amounts of $279,847 and $279,722 in petitioners Ira and Tracy Nathel's and in petitioners Sheldon and Ann M. Nathel's 2001 joint Federal income taxes. These cases have been consolidated for purposes of briefing and opinion.

In calculating petitioners' ordinary income on receipt of $1,622,050 in loan payments that petitioners received from two S corporations, the underlying...

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