Rebecca Jo Reser 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 that taxpayer with law degree had an education that “albeit advanced, provided her with no special knowledge of complex tax issues”
• explaining that one of the relevant factors in determining whether a bank loaned money to a taxpayer individually is whether the promissory note was executed by taxpayer alone or with his corporation
• finding that taxpayer-wife’s law degree did not provide special knowledge of complex tax issues
• finding that taxpayer-wife’s law degree did not provide special knowledge of complex tax issues
• “[I]n the 1980’s, it was common knowledge that investors could legally obtain large tax benefits through clever investment strategies.”
• taxpayer worked full time as a lawyer and “was the family’s sole source of financial support,” but was not significantly involved in finances of husband’s professional corporation

Source: CourtListener parenthetical corpus (CC0).