Legal Opinion
Zachary H. Sacks and Salley Sacks v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 6, 1996No. 94-70756PublishedCited by 31 opinions
1Opinion of the Court
GOODWIN, Circuit Judge:
Zachary and Salley Sacks appeal an order imposing penalties for the negligent underpayment of taxes. 26 U.S.C. §§ 6653(a) and 6661(a). We affirm the judgment of the Tax Court.
I
The facts of this case are set out in detail in the Tax Court’s opinion. We summarize the most pertinent ones here.
The Sacks claimed investment losses and deductions for 1981 and 1982 from their participation in Far West Drilling Associates (FWDA). FWDA is a limited partnership formed in Utah on December 4, 1980. According to its May 11, 1981 offering memorandum, FWDA was to engage in (1) a…
2Cases cited11 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- David G. Collins Pamela Collins Bernie Gates Maureen Gates Anne Hamsley and David Dister v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Harold Chakales Linda Carol Chakales v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1996
6 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Sparkman v. CommissionerCourt of Appeals for the Ninth Circuit · 2007
- Gary D. Hansen Johnean F. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Blum v. CommissionerCourt of Appeals for the Tenth Circuit · 2013
- Richard Dykstra Julia Dykstra v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
- Swanson v. Comm'rUnited States Tax Court · 2009
26 more not listed; retrieve them via the Exa API.