United States of America v. Taylor

Eli, Janie, Peter, Carolina, Anthony, and Bonnie Sleiman (together, "appellants") appeal three orders of the United States Tax Court denying their petitions to redetermine their tax liability for the years 1991 and 1992. Their consolidated appeals require us to decide two issues: whether the tax court erred in determining that Eli and Peter could not increase their adjusted bases in S corporations they owned by the amount of loans to the corporations that they personally had guaranteed, and whether the tax court properly upheld the Commissioner of Internal Revenue ("Commissioner")s reallocation of Anthonys basis in a piece of real property.