106 Ltd. v. Commissioner, IRS

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that “the improbable tax advantages offered by the tax shelter” should have alerted a taxpayer, who had significant business experience, to the shelter’s illegitimacy
• noting that the Tax Court’s “credibility determinations are entitled to the greatest deference” (quotation and citation omitted)
• “[T]he improbable tax advantages offered by the tax shelter — a $1 million dollar loss from a transaction that earned [the taxpayer] $10,000 (less [his attorney’s] fees

Source: CourtListener parenthetical corpus (CC0).