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PERACCHI v. C.I.R.

No. 96-70606.

143 F.3d 487 (1998)

Donald J. PERACCHI; Judith E. Peracchi, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 29, 1998.

Attorney(s) appearing for the Case

Craig A. Houghton, Baker, Manock & Jensen, Fresno, California, for the petitioners-appellants.

Bruce Ellisen, Tax Division, United States Department of Justice, Washington, DC, for the respondent-appellee.

Before: MAYER, Chief Judge, KOZINSKI and FERNANDEZ, Circuit Judges.

Opinion by Judge KOZINSKI; Dissent by Judge FERNANDEZ.

KOZINSKI, Circuit Judge:

We must unscramble a Rubik's Cube of corporate tax law to determine the basis of a note contributed by a taxpayer to his wholly-owned corporation.

The Transaction

The taxpayer, Donald Peracchi,1 needed to contribute additional capital to his closely-held corporation (NAC) to comply with Nevada's minimum premium-to-asset ratio for insurance...

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