Legal Opinion
Donald Merino Rosemarie Merino v. Commissioner of Internal Revenue, Defendents
Court of Appeals for the Third Circuit
Decided October 29, 1999No. 98-7159PublishedCited by 47 opinions
1Opinion of the Court
OPINION OF THE COURT
McKEE, Circuit Judge.
Donald and Rosemarie Merino appeal the ruling of the United States Tax Court sustaining the Commissioner of Internal Revenue’s imposition of additional taxes for their negligent underpayment of tax pursuant to IRC §§ 6653(a) and (a)(1), and for underpayment of tax attributable to a valuation overstatement pursuant to IRC § 6659. 1 The Commissioner’s decision was based upon the taxpayers’ attempt to claim tax credits and losses purportedly resulting from their 1981 investment in Northeast Resource Recovery Associates (“Northeast”) a tax shelter that was…
2Cases cited19 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
14 more not listed; retrieve them via the Exa API.
3Cited by47 opinions
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Fidelity International Currency Advisor a Fund, LLC Ex Rel. Tax Matters Partner v. United StatesCourt of Appeals for the First Circuit · 2011
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
42 more not listed; retrieve them via the Exa API.