On February 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Bordelon v. Commissioner (T.C. Memo. 2020-26). The issues presented in Bordelon v. Commissioner were (1) whether the petitioner-husband’s personal guarantee of a loan established sufficient amounts “at risk” under IRC § 465 to permit deduction of a loss related to a wholly-owned LLC in 2008; and (2) whether petitioner-husband’s personal guarantee of a second loan increased his basis in a second wholly owned LLC under IRC § 704(d), thereby establishing sufficient “at risk” amounts under IRC § 465 to entitle him to deduct in 2011 his share of suspended losses from 2008. Between a Rock and a Hard Place in Bordelon v. Commissioner Rock Bordelon was in the healthcare business. His name wasn’t Peter, and he did not simply go by “Rock.” No, dear reader, the name his momma gave him was Rock. It’s likely…