Legal Opinion

Dixon v. Comm'r

United States Tax Court

Decided March 23, 2009No. Nos. 9382-83, 15907-84, 30979-85Published

Ps' cases were three of the Kersting tax shelter test cases that were included in Dixon v. Commissioner, T.C. Memo. 1991-614 (Dixon II), vacated and remanded sub nom. DuFresne v. Commissioner, 26 F.3d 105 (9th Cir. 1994) (DuFresne), on remand Dixon v. Commissioner, T.C. Memo. 1999-101 (Dixon III), supplemented by T.C. Memo. 2000-116 (Dixon IV), revd. and remanded 316 F.3d 1041, 1047 (9th Cir. 2003) (Dixon V), on remand T.C. Memo. 2006-90 (Dixon VI), supplemented by T.C.

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Ps' cases were three of the Kersting tax shelter test cases that were included in Dixon v. Commissioner, T.C. Memo. 1991-614 (Dixon II), vacated and remanded sub nom. DuFresne v. Commissioner, 26 F.3d 105 (9th Cir. 1994) (DuFresne), on remand Dixon v. Commissioner, T.C. Memo. 1999-101 (Dixon III), supplemented by T.C. Memo. 2000-116 (Dixon IV), revd. and remanded 316 F.3d 1041, 1047 (9th Cir. 2003) (Dixon V), on remand T.C. Memo. 2006-90 (Dixon VI), supplemented by T.C. Memo. 2006-190 (Dixon VIII) (on appeal Dec. 28, 2006, and Jan. 3, 2007). The protracted and multiplied proceedings in these…

1Opinion of the Court

JERRY AND PATRICIA A. DIXON, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Dixon v. Comm'r

Nos. 9382-83, 15907-84, 30979-85

United States Tax Court

132 T.C. 55; 2009 U.S. Tax Ct. LEXIS 5; 132 T.C. No. 5;

March 23, 2009. 30979-85., Filed

Dixon v. Comm'r, T.C. Memo 2006-190, 2006 Tax Ct. Memo LEXIS 193 (T.C., 2006)

Ps' cases were three of the Kersting tax shelter test cases that were included in Dixon v. Commissioner, T.C. Memo. 1991-614 (Dixon II), vacated and remanded sub nom. DuFresne v. Commissioner, 26 F.3d 105 (9th Cir. 1994) (DuFresne), on remand Dixon v. Commissioner,…

2Cases cited106 opinions

  1. Hensley v. EckerhartSupreme Court of the United States · 1983
  2. Blum v. StensonSupreme Court of the United States · 1984
  3. Chambers v. Nasco, Inc.Supreme Court of the United States · 1991
  4. Arizona v. FulminanteSupreme Court of the United States · 1991
  5. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989

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