Hammer, Raymond Clinton

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 Treas. Reg. § 1.6664-4(c)(2), 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

Source: CourtListener parenthetical corpus (CC0).