Joseph P. Chamberlain and D. Kathleen Chamberlain 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 taxpayer can not rely on someone with no knowledge of the relevant tax matters to establish good faith reliance on professional advice
• holding taxpayer reasonably relied on advice of partnership accountant who, in turn, relied on the opinion letter from the offering materials
• reversing penalty assessment where “[t]he [tax] expert advised that there was ‘a good faith, supportable position’ concerning the deductibility of the loss.”
• “The record reflects no basis for a finding or conclusion that it was not reasonable for taxpayers to rely on the expert’s advice.”
• “The reliance must be objectively reasonable; taxpayers may not rely on someone with an inherent conflict of interest, or someone with no knowledge concerning that matter upon which the advice is given.” (footnotes omitted)

Source: CourtListener parenthetical corpus (CC0).