Fredric A. Gardner v. Commissioner

145 T.C. No. 6

UNITED STATES TAX COURT FREDRIC A. GARDNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ELIZABETH A. GARDNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 14877-13L, 2940-14L.1 Filed August 26, 2015. 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…