Legal Opinion
American Technology Resources v. United States
Court of Appeals for the Third Circuit
Decided January 17, 1990No. Nos. 89-1431 to 89-1434PublishedCited by 10 opinions
1Opinion of the Court
OPINION OF THE COURT
NYGAARD, Circuit Judge.
This is an appeal from a judgment in favor of the United States. The district court adjudicated appellants liable under 26 U.S.C. § 6700, the penalty provision for promoting abusive tax shelters for selling grossly overvalued distributorship franchises. Appellants raise two issues: first, whether the district court erred in concluding that the value of the American Technology Resources, (“ATR”), distributorships was “directly related” to the amount of any deduction allowable under the Internal Revenue Code; and, second, whether the district court…
2Cases cited7 opinions
- Aloe Coal Company and Commercial Union Insurance Company v. Clark Equipment Co.Court of Appeals for the Third Circuit · 1987
- Michael McMonagle v. Northeast Women's Center, IncSupreme Court of the United States · 1989
- Hammond, Ruth L., Administratrix of the Estate of James B. Hammond, Sr., and Ruth L. Hammond, in Her Own Right v. International Harvester Co.Court of Appeals for the Third Circuit · 1982
- Linkstrom v. Golden T. FarmsCourt of Appeals for the Third Circuit · 1989
- Strick Corporation, Appellant/cross-Appellee v. United States of America, Appellee/cross-AppellantCourt of Appeals for the Third Circuit · 1983
2 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Dunn v. HOVICCourt of Appeals for the Third Circuit · 1993
- United Jersey Bank v. CS Associates (In Re CS Associates)United States Bankruptcy Court, E.D. Pennsylvania · 1990
- DeLuca Ex Rel. DeLuca v. Merrell Dow Pharmaceuticals, Inc.District Court, D. New Jersey · 1992
- Rogers v. Raymark Industries, Inc.Court of Appeals for the Ninth Circuit · 1991
- Amy Deluca v. Merrell Dow Pharmaceuticals, Inc.Court of Appeals for the Third Circuit · 1990
5 more not listed; retrieve them via the Exa API.