Legal Opinion
William E. Gustashaw, Jr. v. Commissioner of IRS
Court of Appeals for the Eleventh Circuit
Decided September 28, 2012No. 11-15406PublishedCited by 27 opinions
1Opinion of the Court
HULL, Circuit Judge:
Although a tax shelter can be legitimate, Petitioner William Gustashaw, Jr., 1 participated in one that was not. Gustashaw claimed substantial tax benefits from the shelter on four consecutive tax returns. The IRS later disallowed Gustashaw’s claim and determined deficiencies in tax and accuracy-related penalties, including gross valuation misstatement penalties and a negligence penalty. Gustashaw conceded the deficiencies in tax, but contested the penalties. The Tax Court affirmed the IRS’s imposition of the penalties. After review and oral argument, we affirm.
I.…
2Cases cited23 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Access Now, Inc. v. Southwest Airlines Co.Court of Appeals for the Eleventh Circuit · 2004
- Commissioner v. LoBueSupreme Court of the United States · 1956
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
18 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Superior Trading, LLC v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- Kerman v. CommissionerCourt of Appeals for the Sixth Circuit · 2013
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- Donald Kipnis v. Bayerische Hypo-Und Vereinsbank, etc.Supreme Court of Florida · 2016
- Highpoint Tower Technology Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019
22 more not listed; retrieve them via the Exa API.