Guy R. Baxter v. Commissioner of IRS
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December 10, 2018
Tax Court Right To Reject Couple's $2.4M Tax Shelter: 4th Circ.
A Fourth Circuit panel has upheld a U.S. Tax Court rejection of a $2.4 million tax shelter scheme, ruling it had no economic substance and the taxpayers should have known it was "too good to be true."
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May 24, 2018
Tax Court Misconstrued Transaction, Couple Tells 4th Circ.
Two taxpayers asked the Fourth Circuit on Wednesday to overturn a U.S. Tax Court ruling that had found a transaction — one the Internal Revenue Service called a "tax-avoidance scheme" — to lack economic substance.
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May 04, 2018
IRS Urges 4th Circ. To Uphold Ruling Against Tax Shelter
A sophisticated investor looking to the economic substance of a loan would not pay more than $2 million in fees to borrow $5.3 million, the IRS told the Fourth Circuit Thursday in an appellate brief seeking to uphold a U.S. Tax Court ruling that a family made the investment solely to generate a tax loss.