Glass v. Comm'r of Internal Revenue
137 cases
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Santa Monica Pictures, LLC, v. Commissioner, Dkt. No. 6163-03.
... ... 2. Distribution Revenue and Expenses 79 ... XI. Transactions with Imperial ... 1989), affg. Glass v. Commissioner [Dec. 43,495], 87 T.C. 1087 (1986); Rice's Toyota World, ... 144 An internal memorandum that Troy & Gould prepared during its due diligence confirms ... ...
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Martuccio v. Commissioner
... ... Unless otherwise noted, all section references are to the Internal Revenue Code as in effect for the years in issue, and all Rule references ... 1989), affg. Glass v. Commissioner [Dec. 43,495], 87 T.C. 1087 (1986). A "factual sham" is a ... ...
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Rasmussen v. Commissioner
... ... 27736-88 ... 2. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to ... 1989), affg. Glass v. Commissioner [Dec. 43,495], 87 T.C. 1087 (1986); Boynton v ... ...
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Strangi v. Commissioner of Internal Revenue
... ... Helvering, 293 U.S. 465, 469, 79 L. Ed. 596, 55 S. Ct. 266 (1935); Yosha v. Commissioner, 861 F.2d 494, 497 (7th Cir. 1988), affg. Glass v. Commissioner, 87 T.C. 1087 (1986). However, the tax effects of a particular transaction are determined by the substance of the transaction rather ... ...
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3 books & journal articles
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Can the battle be won? Compaq, the sham transaction doctrine, and a critique of proposals to combat the corporate tax shelter dragon.
...the residual value of the equipment involved in the transaction was not sufficient to earn [the taxpayer] a profit"); Glass v. Comm'r, 87 T.C. 1087, 1157 (1986) (describing an option straddle transaction that was found to lack economic substance as having produced a loss in year one and a g......
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Pretransaction restructuring using an F reorg.
...tax deductions are substantive shams, regardless of the motive of the taxpayer" (Kirchman, 862 F.2d at 1492 (11th Cir. 1989), aff'g Glass, 87 T.C. 1087 (1986)). (See also Mahoney, 808 F.2d 1219 (6th Cir. 1987), aff'g Forseth, 85 T.C. 127 (1985); and Shriver, 899 F.2d 724 (8th Cir. However, ......
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Discharge of Tax Shelter Liability in Bankruptcy
...Treas. Reg. § 1.6661-5(b)(1). 24. See, Smith v. Comm'r, 78 T.C. 350 at 394; Fox v. Comm'r, 87 T.C. 1001 at 1021; Glass v. Comm'r, 87 T.C. 1087 at 1175. 25. See, Pomponio, supra, note 20. Column Ed.: J. William Denver---292-2900 This column is prepared by the Taxation Section of the Colorado......