Legal Opinion
Reddam v. Commissioner
Court of Appeals for the Ninth Circuit
Decided June 13, 2014No. 12-72135PublishedCited by 14 opinions
1Opinion of the Court
OPINION
HURWITZ, Circuit Judge:
John Paul Reddam claimed a deduction on his 1999 tax return of $50,164,421 for a capital loss purportedly generated by several Cayman Islands entities. The Commissioner of Internal Revenue disallowed the deduction, finding that the transaction lacked economic substance. After a bench trial, the Tax Court affirmed. Reddam v. Comm’r, No. 22557-08, 2012 WL 1215220 (T.C. Apr. 11, 2012). We have jurisdiction over Reddam’s appeal under 26 U.S.C. § 7482(a)(1) and affirm.
I. Factual Background
A. Reddam’s $48,500,000 capital tax gain and search for tax reduction strategies
I…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. DavisSupreme Court of the United States · 1970
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
7 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Slone Revocable Trust v. CirCourt of Appeals for the Ninth Circuit · 2015
- Celia Mazzei v. CommissionerUnited States Tax Court · 2018
- Cross Refined Coal, LLC v. Cmsnr. IRSCourt of Appeals for the D.C. Circuit · 2022
- Estate of Marshall v. Comm'rUnited States Tax Court · 2016
- Endeavor Partners Fund, LLC, Delta Currency Trading, LLC, Tax Matters Partner v. CommissionerUnited States Tax Court · 2018
9 more not listed; retrieve them via the Exa API.