Annie Sam v. Donald Thompson

How courts have described this case

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

• taking judicial notice of 1974 and 1975 Forms W-4E, Exemption From Withholding, and related instructions
• suggesting the importance of \capitalization averages\ in the relevant business when analyzing the alleged thin capitalization of a corporation
• declining to impute a debt instrument in the transaction given that the taxpayer was a “highly sophisticated businessman” who was “fully cognizant of the significance of a formally executed note and underlying security to a lender”
• when he negotiated stock sale on his own behalf, transferred stock to his corporation, then had corporation sell stock, taxpayer failed to show that corporation sold stock for its own benefit

Source: CourtListener parenthetical corpus (CC0).