Myron Barlow and Arlene Barlow 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.

• finding that the IRS is authorized to assess and collect TMT interest without first issuing a notice of deficiency asserting the taxpayer’s liability for the interest
• noting “that courts have found that a taxpayer is negligent if he puts his faith in a scheme that, on its face, offers improbably high tax advantages, without obtaining an objective, independent opinion on its validity”
• noting “that courts have found that a taxpayer is negligent if he puts his faith in a scheme that, on its face, offers improbably high tax advantages, without obtaining an objective, independent opinion on its validity”
• “[R]eliance must be reasonable and the taxpayer must show that the accountant had all the necessary information to make an informed decision.”
• “[R]eliance must be reasonable and the taxpayer must show that the accountant had all the necessary information to make an informed decision.”
• “courts have found that a taxpayer is negligent if he puts his faith in a scheme that, on its face, offers improbably high tax advantages, without obtaining an objective, independent opinion on its validity”

Source: CourtListener parenthetical corpus (CC0).