Larry Austin v. Commissioner of IRS
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August 21, 2020
4th Circ. Won't Reconsider $41M Stock Surrender Tax Battle
The Fourth Circuit won't reconsider its decision that business partners in a distressed-debt company are liable for taxes they attempted to avoid by selling stock to themselves, resulting in $41.2 million in gains, according to an order Friday.
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August 10, 2020
4th Circ. Urged To Reconsider $41M Stock Surrender Tax Row
The Fourth Circuit should reconsider finding business partners in a distressed-debt company liable for taxes on $41.2 million in gains that they avoided by selling stock to themselves, the appeals court was told in a rehearing petition.
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June 23, 2020
4th Circ. Affirms Stock Improperly Sold To Avoid Tax On $41M Gain
Business partners in a distressed-debt company improperly sold stock to themselves to avoid taxes on $41.2 million in gains, the Fourth Circuit said in an opinion Tuesday, affirming a U.S. Tax Court decision.
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March 28, 2019
Stock Sale 'Utterly Devoid' Of Economic Substance, 4th Circ. Told
The president and a business partner of a distressed-debt business sold their company's stock to themselves in a transaction "utterly devoid" of economic substance to avoid taxes on $45.7 million in gains, the IRS has told the Fourth Circuit.
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February 11, 2019
Tax Court Erred In Stock Surrender Ruling, 4th Circ. Told
The president of a distressed debt loan business in North Carolina and the estate of his now-deceased business partner told the Fourth Circuit Monday that the U.S. Tax Court wrongly found their surrender of restricted shares to lack economic substance.