Stobie Creek Investments LLC v. United States

How courts have described this case

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

• concluding that the partnership could raise a reasonable-cause defense under § 6664(c) “based on the actions of its managing partner”
• holding that advice relied upon must not be based on any “unreasonable factual or legal assumptions” given that the “reasonableness of any reliance turns on the quality and objectivity of the advice”
• noting that to determine whether -12- a transaction has potential for profit, its expected non-tax income must be compared with the expected operating “costs and fees”
• unreasonable to rely on professional advisor if his “role as a promoter of the [Son of BOSS] strategy was evident”
• “[Transaction] lacked economic reality ... [because] there was no reasonable possibility that the FXDOTs would return a profit.”
• “A transaction lacks ‘economic reality’ when the tax result . . . is ‘purely fictional.’”

Source: CourtListener parenthetical corpus (CC0).