David Bruce McMahan v. Commissioner of Internal Revenue

How courts have described this case

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

• noting that special circumstances “arise as a result of factors beyond a taxpayer’s power to control”
• stating that the taxpayer “may well be able to recover the amount of the penalty he must pay from his attorney through a malpractice action or a claim for breach of fiduciary duty under state law”
• considering elements constituting reasonable cause for late filings under section 6651(a)(1)
• \[R]eliance on a mistaken legal opinion of a competent tax adviser--a lawyer or accountant--that it was unnecessary to file a return constitutes reasonable cause\
• \reliance on a mistaken legal opinion of a competent tax adviser—a lawyer or accountant—that it was unnecessary to file a return constitutes reasonable cause\
• \reliance on a mistaken legal opinion of a competent tax adviser—a lawyer or accountant—that it was unnecessary to file a return constitutes reasonable cause\

Source: CourtListener parenthetical corpus (CC0).