Legal Opinion
John F. Jackson, Jr., and Shirley Jackson v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided June 10, 1992No. 91-9017PublishedCited by 21 opinions
1Opinion of the Court
SEYMOUR, Circuit Judge.
Petitioners John and Shirley Jackson appeal the judgment of the United States Tax Court upholding the Commissioner’s refusal to allow a claimed $15,500 deduction for the 1982 tax year. The Tax Court held that the transaction underlying the deduction was a sham, not recognizable for tax purposes. See I.R.C. § 6621(c) (1988). 1 The court relied heavily on its prior opinion in Moore v. Commissioner, 85 T.C. 72 (1985). On appeal, the Jacksons argue that the Tax Court failed to distinguish their case from Moore and that this failure requires reversal. We disagree and affirm.
A…
2Cases cited6 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Cherin v. CommissionerUnited States Tax Court · 1987
- James v. CommissionerCourt of Appeals for the Tenth Circuit · 1990
- Daniel B. Nickeson and Enid C. Nickeson Norman E. Kuhl and Nancy J. Kuhl v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
- Bohrer v. CommissionerCourt of Appeals for the Tenth Circuit · 1991
1 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- United States v. William Hugh FlemingCourt of Appeals for the Tenth Circuit · 1994
- James B. Thomas, Plaintiff-Appellee/cross-Appellant v. United States of America, Defendant-Appellant/cross-AppelleeCourt of Appeals for the Sixth Circuit · 1999
- Samuel Anderson and Mary Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995
- Keeler v. CommissionerCourt of Appeals for the Tenth Circuit · 2001
16 more not listed; retrieve them via the Exa API.