William E. Gustashaw, Jr. v. Commissioner of IRS

How courts have described this case

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

• finding that \unbelievable benefits offered by the CARDS transaction\ weighed against finding reasonable reliance
• discussing the one-year actual duration of the CARDS loan provided in that case by a German bank that had participated in other Chenery CARDS transactions
• stating, in the context of a different penalty provision, “The most important factor . . . is the ‘extent of the taxpayer’s effort to assess [its] proper tax liability.” (quoting Treas. Reg. § 1.6664-4(b)(1))
• “This rule rests upon the fact that the abusive tax shelter is built upon the basis misstatement, and the transaction’s lack of economic substance is directly attributable to that misstatement.”
• hold- ing that an overvaluation penalty should apply even when the value of the deduction is determined to be zero because the under- lying transaction lacks any economic substance
• “A taxpayer may meet his burden by showing that he reasonably relied in good faith on the advice of an independent professional, such as a tax advisor, lawyer, or accountant, as to the transaction’s tax treatment.”

Source: CourtListener parenthetical corpus (CC0).