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UNITED STATES v. PHILATELIC LEASING, LTD.

Nos. 763, 817, Dockets 85-6198, 85-6200.

794 F.2d 781 (1986)

UNITED STATES of America, Plaintiff-Appellee, v. PHILATELIC LEASING, LTD., Melvin Hersch, and Hambrose Stamps, Ltd., Defendants-Appellants.

United States Court of Appeals, Second Circuit.

Decided June 26, 1986.

Attorney(s) appearing for the Case

Abram Chayes, Cambridge, Mass. (Roberts & Holland, New York City, Doros & Blessey, P.C., New York City, Jesse G. Silverman, Jr., Richard A. Levine, of counsel), for defendants-appellants.

William J. Brennan, Sp. Asst. U.S. Atty., New York City (Rudolph W. Giuliani, U.S. Atty., for S.D.N.Y., Gerald T. Ford, Steven E. Obus, Asst. U.S. Attys., of counsel), for plaintiff-appellee.

Before OAKES, WINTER and MINER, Circuit Judges.

OAKES, Circuit Judge:

The sale of tax shelters, by which taxpayers/investors obtain credits and deductions in return for investments involving risk, has lent itself to sufficient abuses to prompt statutory reform separate from the tax reform presently being discussed in the halls of Congress. The Tax Equity and Fiscal Responsibility Act of 1982 ("TEFRA"), Pub.L. No. 97-248, 96 Stat. 324 (pertinent portions codified in scattered...

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