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BAILEY v. C.I.R.

No. 84-1134.

756 F.2d 44 (1985)

William E. BAILEY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided March 5, 1985.

Attorney(s) appearing for the Case

Harry J. Kaplan (argued), San Jose, Cal., for petitioner-appellant.

Robert B. Miscavich (argued), Fred T. Goldberg, Jr. — Lead Counsel, Chief Counsel, Glenn L. Archer, Jr. — Lead Counsel, Michael L. Paup, Tax Div., Dept. of Justice, Farley P. Katz, Ann B. Durney, Washington, D.C., for respondent-appellee.

Before KEITH, JONES and KRUPANSKY, Circuit Judges.

KRUPANSKY, Circuit Judge.

Taxpayer William E. Bailey (Bailey) appeals from an order of the tax court granting summary judgment in favor of the Commissioner and holding that taxpayer is not entitled to the benefits of the remedial provisions of § 1341 of the Internal Revenue Code (I.R.C.).

Bailey was an officer, shareholder and director of Bestline Products, Inc., and Bestline Products Corporation (Bestline), a "pyramid" multi-level direct sales organization...

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