Legal Opinion
Joseph P. Chamberlain and D. Kathleen Chamberlain v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided October 24, 1995No. 94-40806PublishedCited by 51 opinions
1Opinion of the Court
POLITZ, Chief Judge:
Taxpayers, Joseph P. and D. Kathleen Chamberlain, 1 appeal the Tax Court’s decision upholding the penalties assessed by the Commissioner of Internal Revenue. We affirm in part and reverse in part.
Background,
Joseph P. Chamberlain became a partner in Great Plains Partners in 1981. The partnership’s principal objective was to enter into forward contracts with First Western Government Securities, Inc. In Freytag v. Commissioner of Internal Revenue 2 we reviewed the program operated by First Western and determined that it was a sham. 3
During taxable year 1981, Great Plains…
2Cases cited10 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- United States v. BoyleSupreme Court of the United States · 1985
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Complaint of Port Arthur Towing Co. on Behalf of M/V Miss CarolynCourt of Appeals for the Fifth Circuit · 1995
5 more not listed; retrieve them via the Exa API.
3Cited by51 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- Streber v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
46 more not listed; retrieve them via the Exa API.