Shami v. Commissioner

How courts have described this case

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

• affirming this Court’s decision not to apply Cohan where taxpayer failed to produce reasonable evidentiary 88 [ ] basis for estimate
• “In short, the supervisor of the direct super- visor of employees who conduct qualified research is not himself engaged in qualified research.”
• “[T]he Cohan rule is not implicated unless the taxpayer proves that he is entitled to some amount of tax ben- efit.”
• “[T]he Cohan rule is not implicated unless the taxpayer proves that he is entitled to some amount of tax ben- efit.”
• “[T]he Cohan rule is not implicated unless the taxpayer proves that he is entitled to some amount of tax ben- efit.”
• “In short, the supervisor of the direct super- visor of employees who conduct qualified research is not himself engaged in qualified research.”

Source: CourtListener parenthetical corpus (CC0).