United States Second Circuit
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
- Published 2018/12/14
Judges
- Raggi
Court
- United States Second Circuit