Kerry W. Illes 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.

• noting importance of taxpayer's education and business experience in determining whether reliance on advisor reasonable
• finding negligence where taxpayer relied on person with financial interest in the venture
• finding negligence where taxpayer relied on person with financial interest in the venture
• declining, where a taxpayer “stipulated that [a] transaction lacked economic substance,” to “make the more difficult determination of the taxpayer’s intent” but suggesting in dicta that section 165(c)(2
• finding negligence where taxpayer relied on person with financial interest in the venture
• formulating a two-part test for deducting investment losses in which “The threshold question is whether the transaction has economic substance. If the answer is yes, the question becomes whether the taxpayer was motivated by profit to participate in the transaction.”

Source: CourtListener parenthetical corpus (CC0).