Rybak v. Commissioner
United States Tax Court
Some of the petitioners entered into four different transactions, all of which were "generic tax shelters." Held: The transactions lacked economic substance, and are to be disregarded for Federal income tax purposes. Further, such transactions are "tax motivated transactions" under sec. 6621(c), I.R.C. 1954. Some of the petitioners also entered into a container leasing transaction, but failed to show that they were entitled the deductions and credits claimed.
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Some of the petitioners entered into four different transactions, all of which were "generic tax shelters." Held: The transactions lacked economic substance, and are to be disregarded for Federal income tax purposes. Further, such transactions are "tax motivated transactions" under sec. 6621(c), I.R.C. 1954. Some of the petitioners also entered into a container leasing transaction, but failed to show that they were entitled the deductions and credits claimed. Some of the petitioners also entered into a franchise program to provide financial services, but petitioners failed to show they were…
1Opinion of the Court
Francis J. Rybak and Joyce A. Rybak, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Rybak v. Commissioner
Docket Nos. 3544-85, 11104-85, 11105-85, 14308-85, 17033-85, 17034-85, 19775-85, 22868-85, 22869-85, 22905-85, 22909-85, 24968-85, 24994-85, 25009-85, 25015-85, 25025-85, 25040-85, 25054-85, 25062-85, 38662-85, 45776-85, 1792-86, 3759-86, 7882-86, 8838-86, 14094-86, 22292-86, 24301-86, 24683-86, 29693-86, 40665-86
United States Tax Court
91 T.C. 524; 1988 U.S. Tax Ct. LEXIS 118; 91 T.C. No. 36;
September 7, 1988; As amended September 27, 1988; As amended January 19, 1989…
2Cases cited16 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Rose v. CommissionerUnited States Tax Court · 1987
- Patin v. CommissionerUnited States Tax Court · 1987
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