2 canonical passages across 2 cases, quoted by 6 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Fidelity International Currency Advisor a Fund, LLC v. United States.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Fidelity International Currency Advisor a Fund, LLC v. United States Anchor | green | “if a partnership is found to be a sham, the partnership should be disregarded, and the partnership's activities are deemed to be engaged in by one or more of the partners.” | 3 |
| 2 | Alpha I, L.P. v. United States | green | “reliance on advice by tax professionals is specifically excluded in deciding whether substantial authority exists for a particular tax treatment.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.