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BARNARD v. C.I.R.

No. 83-1777.

731 F.2d 230 (1984)

John W. BARNARD & June W. Barnard, Earl D. Kay, Jr. & Nancy O. Kay, Joseph J. Allen & Jennene S. Allen, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided April 5, 1984.

Attorney(s) appearing for the Case

John D. Houston, II, Roger G. Rulong, Jr., Michael J. Dempster, Houston, Cohen, Harbaugh & Lippard, Pittsburgh, Pa., on brief, for appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Ann Belanger Durney, Bruce R. Ellisen, Tax Division, Dept. of Justice, Washington, D.C., on brief, for appellee.

Before WIDENER, MURNAGHAN and ERVIN, Circuit Judges.

MURNAGHAN, Circuit Judge:

Sixteen taxpayers (individuals or husband and wife)1 involved in the same transactions designed to provide them with income "tax shelters" found their cases consolidated before the United States Tax Court. In a comprehensive opinion filed May 18, 1983, Judge Arthur L. Nims, III upheld the assessments of income tax deficiencies for the years involved (1975, 1976 and 1977) in the case of each of the taxpayers. ...

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