The IAS Court properly rejected parol evidence offered to show that the promissory notes and security agreements in issue were fraudulent shams to defraud the IRS, entered into to make what was actually a gift, or at most a conditional loan, look like an unconditional promise to pay (see, Phillips v Cioffi,
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.