Neal Crispin v. Commissioner of Internal Reven

OPINION OF THE COURT

JORDAN, Circuit Judge.

Neal D. Crispin appeals the decision of the United States Tax Court that he was not entitled to an ordinary loss deduction for his participation in a Custom Adjustable Rate Debt Structure (“CARDS”) transaction and that he is liable for an accuracy-related penalty under § 6662 of the Internal Revenue Code (“I.R.C.”). 1 The Tax Court disallowed the claimed loss on the grounds that Crispin’s CARDS transaction lacked economic substance and held that he could not avoid the penalty because he had not relied reasonably or in good faith on the advice of an…