Donald Merino Rosemarie Merino v. Commissioner of Internal Revenue, Defendents

How courts have described this case

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

• stating that any new matter must be proved by a preponderance of the evidence
• stating that any new matter must be proved by a preponderance of the evidence
• stating that any new matter must be proved by a preponderance of the evidence
• noting that the parties had stipulated that the fair market value of the asset (which the Court appears to have used as a proxy for cost basis) was less than $50,000
• “[W]henever a taxpayer knowingly invests in a tax avoidance entity which the taxpayer should know has no economic substance, the valuation overstatement penalty is applied as a matter of course.”

Source: CourtListener parenthetical corpus (CC0).