Legal Opinion
Napoliello v. Commissioner
Court of Appeals for the Ninth Circuit
Decided August 23, 2011No. 09-72389PublishedCited by 24 opinions
1Opinion of the Court
OPINION
NOONAN, Circuit Judge:
Michael Napoliello appeals the United States Tax Court’s decision in favor of the Commissioner of Internal Revenue. We have jurisdiction under 26 U.S.C. § 7482(a), and we affirm.
FACTS
This case arises from the Internal Revenue Service’s (“IRS”) investigation of a tax shelter. The type of shelter is known as a “Son-of-BOSS” (being a variant of the Bond and Options Sales Strategy (“BOSS”) shelter). Son-of-BOSS tax shelters involve a series of transactions connected to offsetting foreign currency options. See generally Desmet v. Comm’r of Internal Revenue, 581 F.3d…
2Cases cited12 opinions
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Kornman & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2008
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
- Desmet v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2009
7 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- 106 Ltd. v. Commissioner, IRSCourt of Appeals for the D.C. Circuit · 2012
- Meruelo v. CommissionerCourt of Appeals for the Ninth Circuit · 2012
- Thompson v. CommissionerUnited States Tax Court · 2011
- Organic Cannabis Foundation v. CirCourt of Appeals for the Ninth Circuit · 2020
- Bedrosian v. Comm'rUnited States Tax Court · 2015
19 more not listed; retrieve them via the Exa API.