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GARDNER v. COMMISSIONER

Docket Nos. 14877-13L, 2940-14L.

145 T.C. 161 (2015)

FREDRIC A. GARDNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ELIZABETH A. GARDNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 26, 2015.

Attorney(s) appearing for the Case

Fredric A. Gardner and Elizabeth A. Gardner, pro sese.

Doreen Marie Susi, Derek S. Pratt, J. Rob Gordon, and Rachael J. Zepeda, for respondent.

Fredric A. Gardner and Elizabeth A. Gardner (petitioners or Gardners) are husband and wife. They marketed and promoted a plan or arrangement involving the use of trusts, limited liability companies (LLCs), and entities known as corporations sole which the Internal Revenue Service (IRS) determined to be an abusive tax shelter. Agreeing...

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