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ROSE v. C.I.R.

No. 88-1012.

868 F.2d 851 (1989)

James L. ROSE and Judy S. Rose, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided February 27, 1989.

Attorney(s) appearing for the Case

Robert L. Ackerson (argued), Kristine Kaiser, Ackerson, Blandford & Kiser, Jeffrey C. Sauer, Louisville, Ky., for petitioners-appellants.

William F. Nelson, I.R.S., Gary R. Allen, Chief Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., Janet K. Jones, William S. Rose, Jr., Richard Farber (argued), for respondent-appellee.

Before KENNEDY, MARTIN and NORRIS, Circuit Judges.

BOYCE F. MARTIN, Jr., Circuit Judge.

James L. and Judy S. Rose, the taxpayers, appeal from the tax court's determination, 88 T.C. 386 (1987). The tax court found that their purchase of "reproduction masters" of Picasso originals from Jackie Fine Arts lacked economic substance apart from anticipated tax benefits. It also concluded that the taxpayers were not entitled to depreciation or miscellaneous deductions or investment tax credits...

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