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William Sennett and Sandra Sennett v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit (1985) | 752 F.2d 428
TL;DR: A former partner repaid his share of a prior-year partnership loss after selling his interest. The court disallowed his deduction, holding that the tax rule allowing for the deduction of repaid losses applies only to current partners.
Legal Significance: This case establishes that a taxpayer must be a partner in the year they repay an excess suspended loss to deduct that loss under 26 U.S.C. § 704(d). Partner status is a prerequisite for utilizing the loss carryover provision.