Kerman v. Commissioner

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that loan transaction lacked economic substance, in part because of its ʺabsurdly high interest rateʺ (internal quotation marks omitted)
• noting that the taxpayer did not have unfettered access to all the loan proceeds under the sham transaction
• noting that the CARDS promotional materials stated that \the taxpayer claims a tax loss ... even though the taxpayer has incurred no corresponding economic loss\
• “[R]egardless of what investment Kerman planned to use the loan proceeds for (if any), financing with [the loan] transaction did not provide him with a reasonable possibility of profit.”
• \[N]o credible business purpose for using such an expensive financing vehicle existed.\

Source: CourtListener parenthetical corpus (CC0).