Shades Ridge Holding Company, Inc. v. United States of America, United States of America v. Sam A. Fiorella and Shades Ridge Holding Company, Inc.

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 federal law and Alabama law on the issue “are so similar that the distinction is of little moment”
• holding corporation liable for taxpayer’s debt applying federal common law
• “Property of the nominee or alter ego of a taxpayer is subject to the collection of the taxpayer’s tax liability.”
• taxpayer used a holding company to hold assets to escape personal tax liability from gambling operation that had been accruing since 1957
• “The issue under either state or federal law depends upon who has ‘active’ or ‘substantial’ control.”
• “The issue . . . depends on who has ‘active’ or ‘substantial’ control.”

Source: CourtListener parenthetical corpus (CC0).