Murfam Farms, LLC, et al. v. United States, 94 Fed. Cl. 235 (Fed. Cl. 2010)

(plaintiff's acquisition by defendant via basis-shifting tax shelter offered by Ernst & Young which sheltered $100 million taxable gain resulted in disallowed losses and 40 percent gross valuation misstatement penalty; reliance on CPA firm's advice not reasonable - it was the same firm that sold them the COBRA tax shelter for $2.5 million).