SAVIANO v. C.I.R.

No. 83-2816.

765 F.2d 643 (1985)

Ernest J. SAVIANO and Margaret Saviano, Appellants, v. COMMISSIONER OF INTERNAL REVENU, Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 18, 1985.


Attorney(s) appearing for the Case

Harold Ungar, Williams & Connolly, Washington, D.C., for appellants.

Farley Katz, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D.C., for appellee.

Before CUMMINGS, Chief Judge, COFFEY, Circuit Judge, and CAMPBELL, Senior District Judge.


WILLIAM J. CAMPBELL, Senior District Judge.

"Gold for Tax Dollars," certainly an alluring phrase, is the title of a tax shelter that has enticed thousands of taxpayers with dreams of large deductions. The plan contemplated the taxpayer investing in a gold mine in Panama (for taxable year 1978) or French Guiana (for taxable year 1979) and obtaining thereby a tax deduction equivalent to four times the actual investment. However, the Commissioner of Internal Revenue...

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