Legal Opinion
August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided August 27, 1993No. 19-80008PublishedCited by 111 opinions
1Opinion of the Court
WALLACE, Chief Judge:
The Internal Revenue Service (IRS) challenged the returns of numerous taxpayers who invested in a tax shelter marketed by Encore Leasing Corporation (Encore). One of them, Wolf, appeals from a decision of the tax court upholding the IRS’s disallowance of several deductions on Wolfs 1979-1982 federal, income tax returns and affirming the IRS’s assessment of additions to tax and penalties. The tax court exercised jurisdic tion pursuant to 26 U.S.C. §§ 6213, 6214, and 7442. We have jurisdiction over Wolfs timely appeal pursuant to 26 U.S.C. §§ 7482(a) and 7483. We affirm.
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Enc…
2Cases cited20 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Surloff v. CommissionerUnited States Tax Court · 1983
- Patin v. CommissionerUnited States Tax Court · 1987
- William S. Skeen and Alison Skeen v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
15 more not listed; retrieve them via the Exa API.
3Cited by111 opinions
- Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Hildebrand v. CommissionerCourt of Appeals for the Tenth Circuit · 1994
- Sparkman v. CommissionerCourt of Appeals for the Ninth Circuit · 2007
- Gary D. Hansen Johnean F. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
106 more not listed; retrieve them via the Exa API.