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Survey Article


In 1999 the Eleventh Circuit Court of Appeals decided several substantive tax cases as well as a number of procedural cases. The substantive tax issues addressed by the court included the definition of "control" under Internal Revenue Code Section 1504(a); whether S corporation shareholders can increase basis in their stock by the amount of guaranteed loans; the allocation of the purchase price of real property among depreciable and nondepreciable assets; employment tax issues; and worthless debt deductions under Internal Revenue Code Section 166. As to procedural issues, the court decided cases relating to remittances made in connection with Form 4868, the statute of limitations for willful evasion of payment of tax, and how bankruptcy stays affect the period for appealing Tax Court decisions.