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
WHITAKER, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax for the years and in the amounts as follows:
Years Amount
1972. $27,425
1973. 18,905
1974. 13,191
1975. 2,740
1976. 1,586
1977. 185
1978. 1,416
By amendment to the answer, respondent asserts that the deficiencies constitute substantial underpayments attributable to tax-motivated transactions within the meaning of section 6621(c),1 formerly section 6621(d). The issues for decision all arise out of petitioner’s investment in a cattle program operated and offered by Southern Star Land & Cattle Co., Inc. (Southern…
2Cases cited19 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
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
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3Cited by145 opinions
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- Larsen v. CommissionerUnited States Tax Court · 1987
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