Skip to main content

United States Second Circuit

Reset A A Font size: Print

Benenson v. Commissioner of Internal Revenue, 16‐2953

Held that a husband and wife were not liable for a 2008 tax deficiency. The IRS had applied the substance‐over‐form doctrine to recharacterize various lawful tax‐avoiding transactions as tax‐generating events for the taxpayers, their adult sons, a family trust, and a family‐controlled corporation. Reversed the tax court.

Appellate Information

  • Decided
  • Published 2018/12/14


  • Raggi


  • United States Second Circuit


Copied to clipboard