Legal Opinion
Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 7, 1993No. 92-1681, 92-1682PublishedCited by 91 opinions
1Opinion of the Court
CONTIE, Senior Circuit Judge.
Petitioners-appellants, Frank C. Pasternak and Judith Pasternak; Anthony J. and Diane Cutaia; and David G. Koehlinger, appeal a Tax Court decision upholding tax deficiencies and penalties against them for the taxable years 1981 and 1982 issued by the Commissioner of Internal Revenue, respondent-appellee.
I
Petitioners are persons who invested in various master recording leasing programs. Four corporations were set up by Misters Barbret, Labbadie, Rosanova, and the Detroit law firm of Patmon and Young (“the promoters”), which became the general managing partner of…
2Cases cited34 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Welch v. HelveringSupreme Court of the United States · 1933
- Neely v. CommissionerUnited States Tax Court · 1985
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
29 more not listed; retrieve them via the Exa API.
3Cited by91 opinions
- Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Glenn A. Mortensen v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
86 more not listed; retrieve them via the Exa API.