Legal Opinion
Kornman & Associates, Inc. v. United States
Court of Appeals for the Fifth Circuit
Decided May 12, 2008No. 06-11422PublishedCited by 79 opinions
1Opinion of the Court
DeMOSS, Circuit Judge:
In these consolidated TEFRA partnership proceedings,1 the Government argues that the Appellants attempted to create an enormous, artificial tax loss that is devoid of any economic content by using the short sale variant of the “Son of BOSS” tax shelter.2 Through a pre-arranged series of transactions involving the short sale of Treasury Notes (T-Notes) and subsequent transfers between a trust, two limited partnerships (LPs), and an individual, the Ettman Family Trust (the Trust) reported a short-term capital loss of approximately $102.6 Million on its 1999 tax return…
2Cases cited54 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Exxon Mobil Corp. v. Allapattah Services, Inc.Supreme Court of the United States · 2005
- Gregory v. HelveringSupreme Court of the United States · 1935
49 more not listed; retrieve them via the Exa API.
3Cited by79 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Murkeldove v. AstrueCourt of Appeals for the Fifth Circuit · 2011
- Marriott International Resorts, L.P. v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
74 more not listed; retrieve them via the Exa API.