People v. Ruibal

How courts have described this case

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

• stating that the legal doctrines delineated in Helmer apply to the short option that was contributed to a partnership along with a long option
• noting that the taxpayer’s knowledge that the firms were financially interested in the implementation of the strategy diminished the reasonableness in relying on their advice
• relying on Neonatology Associates, P.A. , holding that the Jenkens & Gilchrist strategy is the type that should appear to be too good to be true
• considering, without discussing the jurisdictional question, whether No. 09-1109 15 the partnership had reasonable cause to claim large losses
• “[T]he concept of reliance on the advice of professionals is a hallmark of the exception for reasonable cause and good faith.”
• a negative expected return indicates “s cant profit potential,” and the transactions therefore must be disregarded for tax purposes

Source: CourtListener parenthetical corpus (CC0).