Ronald Dwight Kunde v. Estate of Bowman

How courts have described this case

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

• stating that “denial of recognition means that such a transaction cannot be the basis for a deductible expense”
• observing that \a transaction that lacks economic substance is not recognized for Federal tax purposes\ and that \denial of recognition means that such a transaction cannot be the basis for a deductible expense\
• observing that “a transaction that lacks economic substance is not recognized for Federal tax purposes” and that “denial of recognition means that such a transaction cannot be the basis for a deductible expense”
• rejecting taxpayer’s claim that funding employee benefits with tax savings was legitimate non-tax business purpose because “[i]f this were sufficient to breathe substance into a transaction whose only purpose was to reduce taxes, every sham tax-shelter device might succeed.”
• rejecting taxpayer’s claim that funding employee benefits with tax savings was legitimate non-tax business purpose because “[i]f this were sufficient to breathe substance into a transaction whose only purpose was to reduce taxes, every sham tax- shelter device might succeed.”
• rejecting taxpayer’s claim that funding employee benefits with tax savings was legitimate non-tax business purpose because “[i]f this were sufficient to breathe substance into a transaction whose only purpose was to reduce taxes, every sham tax- shelter device might succeed.”

Source: CourtListener parenthetical corpus (CC0).