Legal Opinion
George v. Zmuda and Walburga Zmuda v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided April 30, 1984No. 83-7374PublishedCited by 320 opinions
1Opinion of the Court
EUGENE A. WRIGHT, Circuit Judge:
Following a program developed by the American Law Association (ALA), the Zmu-das set up three foreign trusts to avoid taxes on the income from properties in the United States. The Tax Court found that these trusts were shams, disallowed certain deductions, and assessed civil penalties.
The petitioners complain that their due process rights were violated by lack of sufficient notice that they should defend the trusts against a theory of sham. They also challenge the legal standard applied by the Tax Court in determining the invalidity of the trusts, the…
2Cases cited21 opinions
- Mullane v. Central Hanover Bank & Trust Co.Supreme Court of the United States · 1950
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. TowerSupreme Court of the United States · 1946
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
16 more not listed; retrieve them via the Exa API.
3Cited by320 opinions
- Freytag v. CommissionerUnited States Tax Court · 1987
- Kenneth Allen Barbara Allen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1991
- Waddell v. CommissionerUnited States Tax Court · 1986
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Ewing v. CommissionerUnited States Tax Court · 1988
315 more not listed; retrieve them via the Exa API.