Howard Gilman 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.

• requiring the plaintiff to demonstrate that a prudent investor could have concluded that there was a realistic opportunity for a profit
• “The lack of economic substance was due in part to the overvaluation, and thus the underpayment was attributable to the valuation overstatement.”
• section 6659 addition to tax applies if a finding of lack of economic substance is \due in part\ to a valuation overstatement
• section 6659 addition to tax applies if a finding of lack of economic substance is \due in part\ to a valuation overstatement
• The lack of economic substance was due in part to the overvaluation, and thus the underpayment was attributable to the valuation overstatement
• section 6659 addition to tax applies if a finding of lack of economic substance is \due in part\ to a valuation overstatement

Source: CourtListener parenthetical corpus (CC0).