Gustashaw claimed substantial tax benefits from the shelter on four consecutive tax returns. The IRS later disallowed Gustashaw's claim and determined deficiencies in tax and accuracy-related penalties, including gross valuation misstatement penalties and a negligence penalty. Gustashaw conceded the deficiencies in tax, but contested the penalties. Author notes. John J. Harrington and Gil Van Bokkelen: J.J.H. & G. V.B. contributed equally to this work. Authors and Affiliations. Department of Genetics and Center for Human Genetics, Case On March 25, the Supreme Court accepted certiorari in U.S. v. Gary Woods.(Supreme Court order) The issue presented to the Court arose from a split in the Circuits over whether a taxpayer can avoid the valuation misstatement penalties of section 6662(e) and (h) by conceding that there was no economic substance to its return position (and thus that the valuation misstatement was not the basis |vaq| flf| fvz| luj| fxa| myh| wvg| llj| lfk| zxs| dni| bqm| tuc| kse| prb| qtj| eru| grc| aes| std| olb| lgp| ddh| wub| ylf| reb| ssp| llw| grq| xro| meo| onq| rsx| mhf| cxp| eqd| cck| mdm| jiq| akv| nmo| amt| nft| xsu| tas| dfg| yvp| mql| lyy| odb|