Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) 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.

• holding that a prudent person would investigate claims when they are likely “too good to be true”
• holding that a reasonably prudent person should investigate claims when they are likely \too good to be true\
• holding reasonably prudent person should investigate claims when they are likely “too good to be true”
• stating that “a reasonably prudent person would have asked a tax advisor if this windfall were not ‘too good to be true’ ”
• holding reasonably prudent person should investigate claims when they are likely \too good to be true\
• stating that “no particular form is required for a valid notice of deficiency”

Source: CourtListener parenthetical corpus (CC0).