Legal Opinion
Blum v. Commissioner
Court of Appeals for the Tenth Circuit
Decided December 18, 2013No. 12-9005PublishedCited by 9 opinions
1Opinion of the Court
JACKSON, District Judge.
I. Introduction
This case comes to us on appeal from a decision of the Tax Court upholding the actions of the Commissioner of the Internal Revenue Service (IRS) invalidating a financial transaction as lacking economic substance and imposing two accuracy-related penalties for underpayment of taxes. We have jurisdiction to hear this appeal under I.R.C. § 7482(a)(1). The intricacies of this offshore financial transaction and the fog of plausible deniability surrounding it cannot make up for the clarity of the big picture: this was a transaction designed to produce nothing…
2Cases cited35 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- United States v. WoodsSupreme Court of the United States · 2013
- Rice's Toyota World, Inc. v. CommissionerUnited States Tax Court · 1983
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3Cited by9 opinions
- Vaughn v. United States of America Internal Revenue Service (In Re Vaughn)Court of Appeals for the Tenth Circuit · 2014
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- Reddam v. CommissionerCourt of Appeals for the Ninth Circuit · 2014
- United States v. Rapower-3, LLCDistrict Court, D. Utah · 2018
- Alternative Carbon Resources v. United StatesCourt of Appeals for the Federal Circuit · 2019
4 more not listed; retrieve them via the Exa API.