United States Tenth Circuit

In an action seeking a tax refund, the district court's order granting the refund is reversed where the transaction giving rise to petitioner's claimed tax loss had no economic substance because the claimed loss generated by the program was structured from the outset to be a complete fiction.

Appellate Information

• Decided 07/23/2010
• Published 07/23/2010

Judges

• Michael R. Murphy

Court

• United States Tenth Circuit

Counsel

• For Appellant:
  
• Richard Farber, Darrell D. Hallett