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WILLIAMS v. KUNZE

No. 85-1784.

806 F.2d 594 (1986)

Ronald WILLIAMS, et al., Plaintiffs-Appellants, v. Robert KUNZE, IRS Agent, et al., Defendants-Appellees.

United States Court of Appeals, Fifth Circuit.

December 24, 1986.

Attorney(s) appearing for the Case

Lawrence N. Bazrod, MacPherson & McCarville, Donald W. MacPherson, Phoenix, Ariz., for plaintiffs-appellants.

William A. Whitledge, Atty., Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Sec., and Charles E. Brookhart, Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendants-appellees.

Before GARZA, DAVIS and JONES, Circuit Judges.

GARZA, Circuit Judge.

Sometime before May of 1984, the Criminal Investigation Division of the Internal Revenue Service conducted an investigation of the activities of several allegedly fraudulent tax shelter schemes organized and operated from the Cayman Islands by United States Tax Planning Services, Ltd. ("USTPS"). The USTPS schemes involved the use of offshore entities and transactions to put funds beyond the reach of the IRS for the purpose of evading income taxes...

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