Mynes v. United States

How courts have described this case

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

• collecting cases in which the Wisconsin courts have employed a substance-over-form analysis in “a variety of contexts, most notably including tax cases”
• finding shareholders liable for tax and penalties where “the [entire] transaction was premised on the assumption that the taxes would not be paid”
• collecting cases supporting the proposition that “[e]very circuit that has addressed [the] question has ... required independent determinations of transferee status under federal law and substantive liability under state law”
• explaining, in the context of a tax dispute applying the substance-over-form theory in tax law, how the economic reality of a complete asset sale can be equivalent to a stock sale
• affirming the Tax Court's finding that a loan to purchase the shares of the target corporation was a sham in part because \the loan was entirely undocumented; there was no promissory note or writing setting forth the terms of the loan\
• dis- regarding one part of a transaction because it lacked eco- nomic substance

Source: CourtListener parenthetical corpus (CC0).