William F. Sullivan and Rosemary C. Sullivan 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.

• only Commissioner can pierce the form of a transaction to determine its economic substance
• The burden is on the taxpayer to overcome this presumption by persuading the finder of fact, by a preponderance of the evidence, that the income tax assessments are erroneous.

Source: CourtListener parenthetical corpus (CC0).