Dirico v. Comm'r

1 Citing case

  1. Rogers v. Comm'r

    Docket No. 30482-13 (U.S.T.C. Apr. 17, 2018)   Cited 1 times   1 Legal Analyses

    Respondent also argues for the first time on brief that Mr. Rogers received $100,000 of the Multicred fee paid by PPI in 2005 and seeks to characterize it as a shareholder distribution taxable to the extent provided by application of the S corporation rules. The taxation of the $100,000 distribution is a new issue not properly raised before trial, and we will not consider it here. Dirico v. Commissioner, 139 T.C. 396, 416 (2012). With respect to the SRI deposit, SRI deducted the $710,366 as consulting fees.See infra Appendix D.