Federal Case

How courts have described this case

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

• disregarding returns on Citicorp notes where economic returns on capital were unaffected by the transaction
• sophisticated investment partnership 10 formed and manipulated solely to generate a capital loss to shelter some of Colgate- Palmolive’s capital gains
• sophisticated investment partnership formed and manipulated solely to generate a capital loss to shelter some of Colgate-Palmolive's capital gains
• Colgate’s “failure to conduct a contemporaneous profit analysis supports] the Tax Court’s conclusion that ACM’s transactions were not designed or reasonably anticipated to yield a pre-tax profit”
• Colgate’s “failure to conduct a contemporaneous profit analysis support[s] the Tax Court’s conclusion that ACM’s transactions were not designed or reasonably anticipated to yield a pre-tax profit”
• “even where a transaction is not intended to serve business purposes, it may give rise to a deduction to the extent that it has objective economic consequences apart from tax benefits”

Source: CourtListener parenthetical corpus (CC0).