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SAGE v. COMMISSIONER

Docket No. 3372-16.

154 T.C. 270 (2020)

154 T.C. No. 12

JASON B. SAGE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 2, 2020.

Attorney(s) appearing for the Case

Craig R. Berne, Milton R. Christensen, and Dan Eller, for petitioner.

Nhi T. Luu, Kelley A. Blaine, and Janice B. Geier, for respondent.

In 2009 petitioner, Jason B. Sage, an Oregon real estate developer, found himself significantly under water with respect to three parcels of land that he indirectly owned through his wholly owned companies—that is, he owed much more to his mortgage lenders than the land was worth. Facing these financial straits, Mr. Sage undertook...

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