United States Tax Court April 6, 2009, No. 21336-06 (Kerzner v. Comm'r)

T.C. Memo. 2009-76

UNITED STATES TAX COURT

MARVIN S. AND THELMA S. KERZNER, Petitioners v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 21336-06. Filed April 6, 2009.

Using proceeds of loans from a wholly owned

partnership, Ps made annual loans of identical amounts to a

wholly owned S corporation, which in turn paid equivalent

amounts of rent back to the partnership.