Legal Opinion
John B. Gainer v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided January 4, 1990No. 88-7502PublishedCited by 74 opinions
1Opinion of the Court
BOOCHEVER, Circuit Judge:
The Commissioner of Internal Revenue (Commissioner) appeals from the Tax Court’s decision sustaining the income tax deficiency against John B. Gainer (Gainer) but declining to impose an addition to tax pursuant to section 6659 of the Internal Revenue Code. 26 U.S.C. § 6659(a). 1 We affirm.
BACKGROUND
The facts are not in dispute. Sometime in late 1981, Gainer purchased a ten percent limited partnership interest in a Food-Source refrigerated controlled atmosphere shipping container from FoodSource Sales Corporation. The total price of the container was $260,000. Gainer…
2Cases cited10 opinions
- Richards v. United StatesSupreme Court of the United States · 1962
- Rybak v. CommissionerUnited States Tax Court · 1988
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Todd v. CommissionerUnited States Tax Court · 1987
- Commissioner v. Asphalt Products Co.Supreme Court of the United States · 1987
5 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Kerry W. Illes v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Gerald Leuhsler, Beverly Leuhsler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
69 more not listed; retrieve them via the Exa API.