Legal Opinion
Werner H. Erhard v. Commissioner Internal Revenue Service, (Three Cases)
Court of Appeals for the Ninth Circuit
Decided February 8, 1995No. 93-70357, 93-70359 and 93-70360PublishedCited by 17 opinions
1Opinion of the Court
O’SCANNLAIN, Circuit Judge:
We are invited to follow the winding paths of circular money movements to determine whether they lead to transactions of economic substance for federal income tax purposes.
I
Werner Erhard has offered a variety of seminars, workshops, and other programs in personal effectiveness since 1971. At that time, Erhard hired tax attorney Harry Mar-golis to be his personal financial and legal advisor. Margolis arranged the formation and financing of Erhard Seminars Training, Inc.
In 1975, Margolis created a new corporation, “est, a.e.c.,” to assume the activities of Erhard…
2Cases cited14 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Knetsch v. United StatesSupreme Court of the United States · 1960
- United States v. ScovilSupreme Court of the United States · 1955
- Alan B. Karme and Laila M. Karme v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
9 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Seymour Sacks Star Sacks v. Commissioner, Internal Revenue Service, Michael R. Geyser Joyce Geyser v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Chimblo v. CommissionerCourt of Appeals for the Second Circuit · 1999
- Harbor Bancorp & Subsidiaries Edward J. Keith Elena Keith v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
- Marlar, Inc., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Ninth Circuit · 1998
- Chimblo v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1999
12 more not listed; retrieve them via the Exa API.