Legal Opinion
George B. Rosenfeld and Harriet Rosenfeld v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 2, 1983No. 998, Docket 82-4176PublishedCited by 17 opinions
1Opinion of the Court
IRVING R. KAUFMAN, Circuit Judge:
For as long as governments have taxed their citizens, individuals have sought to minimize their tax burdens. On occasion, members of the public have employed elaborate devices to defer taxes or shift income to their associates and relatives in lower tax brackets. When such schemes completely lack legitimate purposes and affect no real economic or beneficial interests, courts have not hesitated to pierce the formal arrangements and examine the substance of the underlying transaction. At the same time, judges have recognized that taxpayers are generally free to…
2Cases cited18 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Helvering v. GregoryCourt of Appeals for the Second Circuit · 1934
- Jicarilla Apache Tribe v. United StatesSupreme Court of the United States · 1979
13 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Long Term Capital Holdings v. United StatesDistrict Court, D. Connecticut · 2004
- United States v. James Sutton Regan, Jack Z. Rabinowitz, Steven Barry Smotrich, Charles M. Zarzecki, Paul A. Berkman, and Bruce Lee NewbergCourt of Appeals for the Second Circuit · 1991
- Tifd Iii-E, Inc. v. United States of America, Docket No. 05-0064-CvCourt of Appeals for the Second Circuit · 2006
- Newman v. CommissionerCourt of Appeals for the Second Circuit · 1990
12 more not listed; retrieve them via the Exa API.