United States Second Circuit

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Chai v. Commissioner of Internal Revenue, 15-1653

In a tax case relating to taxpayer-plaintiff's underreporting of income in his 2003 tax return, principally in connection with a $2 million payment plaintiff received for his role in a now‐defunct tax‐shelter scheme, the Tax Court's judgment is: 1) affirmed in part as to the portion of the Tax Court's order upholding the self‐employment tax deficiency; 2) reversed in part as to the portion of the Tax Court's order upholding the accuracy‐related penalty; and 3) vacated in part as to the Tax Court's jurisdictional ruling where plaintiff concedes that the $2 million payment is fully taxable.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2017/03/20

Judges

  • WESLEY

Court

  • United States Second Circuit

Counsel


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