James L. Rose and Judy S. Rose 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.

• following Rice's Toyota World, Inc. v. Commissioner , 752 F.2d 89 , 96 (4th Cir. 1985) , revg. in part 81 T.C. 184 (1983)
• declining to adopt the “generic tax shelter” analysis “because it does not aid [the Court] in the basic inquiry as to whether the transaction has any practicable economic effects other than the creation of income tax losses,” which is “the proper standard”
• \The requirement of a profit objective is not one of the limitations in section 163 on the deduction of interest actually paid.\

Source: CourtListener parenthetical corpus (CC0).