Gardner v. Comm'r
United States Tax Court
Ps, husband and wife, marketed and promoted a plan involving the use of entities known as corporations sole. The Internal Revenue Service (IRS) determined this plan to be an abusive tax shelter. Agreeing with the IRS, the U.S.
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Ps, husband and wife, marketed and promoted a plan involving the use of entities known as corporations sole. The Internal Revenue Service (IRS) determined this plan to be an abusive tax shelter. Agreeing with the IRS, the U.S. District Court for the District of Arizona (District Court) found that Ps (1) sold more than 300 of these plans and (2) engaged in conduct that violated the provisions of I.R.C. sec. 6700 in that they made false/fraudulent statements as to the availability of tax benefits that could be derived therefrom. The District Court enjoined Ps from further promoting this plan…
1Opinion of the Court
FREDRIC A. GARDNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ELIZABETH A. GARDNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gardner v. Comm'r
Docket Nos. 14877-13L, 2940-14L.1
United States Tax Court
145 T.C. 161; 2015 U.S. Tax Ct. LEXIS 36; 145 T.C. No. 6;
August 26, 2015, Filed
Gardner v. Comm'r, T.C. Memo 2013-67, 2013 Tax Ct. Memo LEXIS 67 (T.C., 2013)
Decisions will be entered for respondent.
Ps, husband and wife, marketed and promoted a plan involving the use of entities known as corporations sole. The Internal Revenue Service (IRS) determined this plan to be…
2Cases cited20 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Sego v. CommissionerUnited States Tax Court · 2000
- Giamelli v. Comm'rUnited States Tax Court · 2007
- Katz v. CommissionerUnited States Tax Court · 2000
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