Task: Wrong Candidate Generation
Input (English): CMI customers pay up to $15,000 to attend “trust academies” run by TES. (Aldridge Trial Tr. at 1287-88, 1295; T. Galley Dep. at 28; S. Galley Decl. ¶¶ 8-9). At these trust academies, customers set up a collection of trusts for the purposes of holding title to customers’ assets and paying their expenses, thereby allowing customers to deduct most of their personal expenses. (RFA 18, 22). CMI and defendant represent that these trusts will allow conversion of up to 97% of income to a tax shelter with “full disclosure to the IRS.” (S. Galley Decl. ¶¶ 14, 22; RFA 16; Fields Dep. at 41-42). The IRS may disregard an entity for tax purposes where such entity lacks economic substance. Richardson, 509 F.3d at 741; see also Coltec Indus., Inc. v. United States, 454 F.3d 1340, 1354 (Fed.Cir.2006) (<HOLDING>). To determine whether a trust has sufficient 
 Holding statements: (A) holding that the economicsubstance doctrine is a judicial tool for effectuating the underlying congressional purpose that despite literal compliance with the statute tax benefits not be afforded based on transactions lacking in economic substance (B) holding complete prohibition on use of crime or accident reports for purpose of soliciting clients too broad a means of effectuating the intended purpose of the law (C) recognizing that an issuer has the primary obligation to pay on letter of credit such that literal compliance with the letter of credits terms for payment is all that is required (D) holding that equitable considerations did not toll the statute of limitations under the tort claims act where plaintiffs conduct was not in strict compliance with congressional waiver of immunity (E) recognizing that the purpose of the setoff doctrine is to prevent circuity of judicial actions
Output (English): recognizing that an issuer has the primary obligation to pay on letter of credit such that literal compliance with the letter of credits terms for payment is all that is required