Legal Opinion
Gardner v. Commissioner
Court of Appeals for the Ninth Circuit
Decided December 1, 2017No. 15-72851 & 15-72852UnpublishedCited by 5 opinions
1Opinion of the Court
MEMORANDUM ***
Fredric A. Gardner and Elizabeth A. Gardner (the “Gardners”) petition for review of a Tax Court order concluding the District Court proceedings and findings in United States v. Gardner, No. CV05-3073-PCT-EHC, 2008 WL 906696 (D.Ariz. Mar. 21, 2008) collaterally estopped the Gard-ners from disputing that they promoted an abusive tax shelter in violation of 26 U.S.C. § 6700, and finding that the IRS established the Gardners sold the corporation sole promotion 1 to no fewer than 47 individuals, subjecting each of the Gardners to a penalty in the amount of $47,000.00. We have…
2Cases cited3 opinions
- Securities & Exchange Commission v. Chenery Corp.Supreme Court of the United States · 1947
- McQUILLION v. SCHWARZENEGGERCourt of Appeals for the Ninth Circuit · 2004
- Gardner v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2017
3Cited by5 opinions
- Martin A. Kapp v. CommissionerUnited States Tax Court · 2019
- Allen R. Davison v. CommissionerUnited States Tax Court · 2020
- Bruce W. Lemay v. CommissionerUnited States Tax Court · 2020
- Friday O. James v. CommissionerUnited States Tax Court · 2020
- Jason E. Shepherd v. CommissionerUnited States Tax Court · 2020