Legal Opinion
Abrams v. Commissioner
Court of Appeals for the Fourth Circuit
Decided April 9, 1986No. 85-1966PublishedCited by 27 opinions
1Opinion of the Court
MURNAGHAN, Circuit Judge:
Converting a sow’s ear into a silk purse' is acknowledgedly difficult. Seeking to convert into a notice of deficiency an Internal Revenue Service letter warning the petitioners that an attempt to utilize, for income tax purposes, a specific “tax shelter” would result in a redetermination leading to an assessment of a deficiency or a reduction or elimination of a refund amounts to an effort of equal audacity and equal futility.
I
A large number of taxpayers invested in a so-called tax shelter known as the “Liberty Financial 1983 Government Securities Trading Strategy.”…
2Cases cited9 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
- Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951
- Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
- Abrams v. CommissionerUnited States Tax Court · 1985
4 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Ramon Portillo and Dolores Portillo v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1991
- Richard D. Bokum, Ii, Margaret B. Bokum v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
- Richard L. Abrams v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Estate of Yaeger v. CommissionerCourt of Appeals for the Second Circuit · 1989
22 more not listed; retrieve them via the Exa API.