context: One relevant inquiry in determining whether plaintiffs had reasonable cause and good faith is whether plaintiffs were involved in a tax shelter.
citation_a.signal: see
citation_a.identifier: 825 F.2d 1292, 1297
citation_a.parenthetical: finding it appropriate for the trial court to refuse to give a good faith instruction to the jury after determining that taxpayer had engaged in a tax shelter
citation_a.sentence: See Hansen v. Comm’r (Hansen), 471 F.3d 1021, 1030-31 (9th Cir.2006) (affirming Tax Court’s finding that taxpayers had engaged in a tax shelter and had not established that they acted with reasonable care notwithstanding indirect reliance on tax professionals); United States v. Solomon (Solomon), 825 F.2d 1292, 1297 (9th Cir.1987) (finding it appropriate for the trial court to refuse to give a good faith instruction to the jury after determining that taxpayer had engaged in a tax shelter); cf. American Boat Co., LLC v. United States (American Boat), 583 F.3d 471, 481-83 (7th Cir.2009) (considering plaintiffs involvement in a tax shelter as one factor in determining the reasonable cause and good faith defense).
citation_b.signal: cf.
citation_b.identifier: 583 F.3d 471, 481-83
citation_b.parenthetical: considering plaintiffs involvement in a tax shelter as one factor in determining the reasonable cause and good faith defense
citation_b.sentence: See Hansen v. Comm’r (Hansen), 471 F.3d 1021, 1030-31 (9th Cir.2006) (affirming Tax Court’s finding that taxpayers had engaged in a tax shelter and had not established that they acted with reasonable care notwithstanding indirect reliance on tax professionals); United States v. Solomon (Solomon), 825 F.2d 1292, 1297 (9th Cir.1987) (finding it appropriate for the trial court to refuse to give a good faith instruction to the jury after determining that taxpayer had engaged in a tax shelter); cf. American Boat Co., LLC v. United States (American Boat), 583 F.3d 471, 481-83 (7th Cir.2009) (considering plaintiffs involvement in a tax shelter as one factor in determining the reasonable cause and good faith defense).