Legal Opinion
Weiner v. United States
District Court, S.D. Texas
Decided December 30, 2002No. CIV.A.H-00-1297PublishedCited by 1 opinion
1Opinion of the Court
MEMORANDUM AND ORDER
ATLAS, District Judge.
A bench trial was held before this Court on December 17, 2002, on Plaintiff Morris Weiner’s claim for a refund of interest for the tax year 1984 assessed by the IRS pursuant to 226 U.S.C. § 6621(c), the Internal Revenue Code (“IRC”) provision authorizing enhanced interest on a substantial underpayment of tax attributable to a tax motivated transaction. 1 After hearing the evidence and argument of counsel, the Court took the matter under advisement. The Court now finds that Weiner had a profit motive in investing in the Travertine Flame Associates…
2Cases cited28 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. JanisSupreme Court of the United States · 1976
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- Helvering v. GregoryCourt of Appeals for the Second Circuit · 1934
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3Cited by1 opinion
- Nevada Partners Fund, LLC Ex Rel. Sapphire II, Inc. v. United StatesDistrict Court, S.D. Mississippi · 2010