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GREENBERG v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 1143-05, 1144-05, 1145-05, 1334-06, 1335-06, 1504-06, 20673-09, 20674-09, 20675-09, 20676-09, 20677-09, 20678-09, 20679-09, 20680-09, 20681-09.

T.C. Memo. 2018-74

DAVID B. GREENBERG, ET AL., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 31, 2018.

Attorney(s) appearing for the Case

Bradley A. Patterson , for petitioners.

Paul Colleran and David A. Lee , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

These cases are about a lawyer and a tax accountant who used a series of complex option spreads to generate millions in tax savings for themselves and their clients. The Commissioner says these transactions look too much like Son-of-BOSS deals—a type of deal this Court has consistently...

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