Another 861 filer has his day in court

[rogfulton]

Tax Court decision published Nov 18.

http://www.ustaxcourt.gov/InOpHistoric/ ... CM.WPD.pdf

Constantine Sakkis filed for 2000 with an 861 entry on line 21 for $642,370. In the decision, it is reported

The Commissioner recoiled, and treated the entire
return as both frivolous and fraudulent. The Sakkises have since
repented of the deduction, but argue that they committed no fraud
by taking it. They also admit that they should have filed a 2001
tax return, which they did only after the Commissioner caught them
and sent a notice of deficiency.

After making a lot of money from a cell-phone company deal

Toward the end of 2000, Sakkis began to look for ways to
avoid paying taxes on the gain. He first tried to use a multitrust
tax shelter, which he learned of during a “capital
preservation” seminar on the remote Pacific island of Vanuatu.

I think you can see where this is headed.

EDIT: Bonus - involvment of Douglas Rosile AND Eduardo Rivera.

[LPC]

The tone of the opinion is rather folksy (e.g., footnote 11: "Although those numbers wandered off the 1040..."), and I'm not sure I've seen an opinion from Holmes before (although he was appointed in 2003).

[JamesVincent]

This was in another thread.

viewtopic.php?f=8&t=6588

[rogfulton]

I searched before posting and didn't find anything. Sorry. That's what I get for searching on the guy's name.

[JamesVincent]

lol... The name isnt mentioned in the other article. Maybe we should make that a standing rule for posting, include the name if the focus of an article is a person so we can search for it.