Legal Opinion
In Re Tax Refund Litigation
District Court, E.D. New York
Decided May 24, 1991No. MDL 87-731 (TCP)PublishedCited by 14 opinions
1Opinion of the Court
MEMORANDUM AND ORDER
PLATT, Chief Judge.
By jury verdict rendered July 11, 1990, the seven plaintiffs were found to have promoted an abusive tax shelter and thus to be liable for the penalty prescribed by I.R.C. § 6700 (1982). By agreement of the parties, this Court will now determine the correct amount of the penalty owed by each of the plaintiffs.
Facts
The tax shelter promoted by the plaintiffs centered around the purchase and subsequent leasing of what the parties have referred to as “book properties.” In broad brush, it was structured in the following manner. Plaintiff Geoffrey Townsend Ltd.…
2Cases cited44 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
39 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Paul F. Belloff v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
- In Re Mdl-731--Tax Refund Litigation Of Organizers And Promoters Of Investment Plans Involving Book Properties Leasing. Barrister AssociatesCourt of Appeals for the Second Circuit · 1993
- Gang v. United StatesDistrict Court, N.D. Illinois · 1992
- Kersting v. United StatesDistrict Court, D. Hawaii · 1992
- Barrister Associates v. United StatesCourt of Appeals for the Second Circuit · 1993
9 more not listed; retrieve them via the Exa API.