August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue Service

How courts have described this case

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

• holding that profit must be the predominant, primary, or principal objective
• holding that profit means economic profit, independent of tax savings
• affirming the Tax Court's section 6673 sanction where the Commissioner had forewarned the taxpayer against litigating frivolous or groundless positions
• explaining there is no clear error if “the tax court’s account of the evidence is plausible in light of the record viewed in its entirety” (brackets omitted)
• setting forth standard of review and concluding that the Tax Court was within its discretion in imposing penalties under § 6673 against taxpayer who pursued frivolous litigation following warning
• setting forth standard of review and concluding Tax Court was within its discretion in imposing penalties under § 6673 against taxpayer who persisted in litigating' frivolous positions following warning

Source: CourtListener parenthetical corpus (CC0).