Legal Opinion
Chai v. Commissioner
Court of Appeals for the Second Circuit
Decided March 20, 2017No. Docket 15-1653 (L); 15-2414 (XAP)PublishedCited by 119 opinions
1Opinion of the Court
WESLEY, Circuit Judge:
Taxpayer Jason Chai’s appeal and the Commissioner of Internal Revenue’s (the “Commissioner”) cross-appeal relate to Chai’s underreporting of - income in his 2003 tax return, principally in connection with a $2 million payment Chai received from Delta Currency Trading, LLC (“Delta”) for his role in a now-defunct tax-shelter scheme. The Commissioner issued Chai a timely notice of deficiency asserting that he owed self-employment tax on the $2 million payment, plus a 20% accuracy-related penalty. The original notice of deficiency did not assert an income-tax deficiency…
2Cases cited39 opinions
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- Singleton v. WulffSupreme Court of the United States · 1976
- Coopers & Lybrand v. LivesaySupreme Court of the United States · 1978
- Catlin v. United StatesSupreme Court of the United States · 1945
- Hormel v. HelveringSupreme Court of the United States · 1941
34 more not listed; retrieve them via the Exa API.
3Cited by119 opinions
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- Mellow Partners, A Partnership v. Cmsnr. IRSCourt of Appeals for the D.C. Circuit · 2018
- Jeff Blau, Tax Matters Partner of RERI Holdings I, LLC v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2019
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