Klieger v. Commissioner
United States Tax Court
Ps were moderate income investors, most of whom had neither a college education nor training in business, financial, and income tax matters. Ps made payments to acquire interests in one or more tax shelter programs that were sham transactions without economic substance. On their Federal income tax returns, prepared by the tax shelter promoter, Ps claimed income tax deductions and credits purportedly attributable to these programs.
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Ps were moderate income investors, most of whom had neither a college education nor training in business, financial, and income tax matters. Ps made payments to acquire interests in one or more tax shelter programs that were sham transactions without economic substance. On their Federal income tax returns, prepared by the tax shelter promoter, Ps claimed income tax deductions and credits purportedly attributable to these programs. Ps conceded all adjustments determined in R's statutory notices of deficiency, but argued on cross-motions for partial summary judgment that they were entitled to…
1Opinion of the Court
KIM S. KLIEGER AND SANDRA J. KLIEGER, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Klieger v. Commissioner
Docket Nos. 14096-90, 14477-90, 15000-90, 15341-90, 15343-90, 24138-90, 10334-91, 10388-91
United States Tax Court
T.C. Memo 1992-734; 1992 Tax Ct. Memo LEXIS 782; 64 T.C.M. (CCH) 1624;
December 30, 1992, Filed
Decisions will be entered for respondent in docket Nos. 15343-90 and 10388-91.
Decisions will be entered under Rule 155 in docket Nos. 14096-90, 14477-90, 15000-90, 15341-90, 24138-90, and 10334-91.
Ps were moderate income investors, most of whom had neither a…
2Cases cited32 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. BoyleSupreme Court of the United States · 1985
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
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- James B. Thomas, Plaintiff-Appellee/cross-Appellant v. United States of America, Defendant-Appellant/cross-AppelleeCourt of Appeals for the Sixth Circuit · 1999