Cherin v. Commissioner
United States Tax Court
Petitioner invested in the Southern Star Land & Cattle Co., Inc., tax shelter program. Held, the purported sales of cattle were lacking in economic substance and the benefits and burdens of ownership were not transferred to petitioner. Held, further, applicability of sec. 6621(c), I.R.C. 1954, determined.
1Opinion of the Court
Ralph Cherin, Petitioner v. Commissioner of Internal Revenue, Respondent
Cherin v. Commissioner
Docket No. 7034-84
United States Tax Court
89 T.C. 986; 1987 U.S. Tax Ct. LEXIS 161; 89 T.C. No. 69;
November 23, 1987. November 23, 1987, Filed
Decision will be entered under Rule 155.
Petitioner invested in the Southern Star Land & Cattle Co., Inc., tax shelter program. Held, the purported sales of cattle were lacking in economic substance and the benefits and burdens of ownership were not transferred to petitioner. Held, further, applicability of sec. 6621(c), I.R.C. 1954, determined.
Judith A. Frankel,…
Also in this document: Concurrence; Concurring in part, dissenting in part; Dissent.
2Cases cited32 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Jasionowski v. CommissionerUnited States Tax Court · 1976
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
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