Desiree Shvonne Marshall v. Bonnie Muller

How courts have described this case

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

• holding that, to constitute “advice” within the meaning of sec. 1.6664-4(c)(2), Income Tax Regs., a communication must simply reflect the adviser’s “analysis or conclusion”
• advice reflects adviser’s analysis or conclusion and taxpayer relied in good faith on adviser’s judgment
• advice reflects adviser's analysis or conclusion and taxpayer relied in good faith on adviser's judgment
• \The taxpayer must show * * * that he 'relied in good faith on the adviser's judgment.'\ (quoting Neonatology Assocs., P.A. v. Commissioner , 115 T.C. at 99 )

Source: CourtListener parenthetical corpus (CC0).