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KLEIN v. C.I.R.

No. 89-3189.

899 F.2d 1149 (1990)

William Randolph KLEIN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

May 1, 1990.

Attorney(s) appearing for the Case

William Randolph Klein, Sarasota, Fla., pro se.

Peter K. Scott, Acting Chief Counsel, I.R.S., Washington, D.C., J. Michael Melvin, Asst. Dist. Counsel, Jacksonville, Fla., James I.K. Knapp, Acting Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Washington, D.C., Gary R. Allen, Michael J. Roach, Chief, Appellate Section, Tax Div., U.S. Dept. of Justice, Michael L. Paup, and Robert S. Pomerance, Deputy Asst. Attys. Gen., Washington, D.C., for respondent-appellee.

Before KRAVITCH and CLARK, Circuit Judges, and ATKINS, Senior District Judge.

ATKINS, Senior District Judge:

Appellant, William Randolph Klein, pro se, appeals from a decision by the United States Tax Court granting partial summary judgment in favor of the Commissioner of Internal Revenue. The Tax Court determined that there were deficiencies in the appellant's income in the taxable years 1979 and 1980 in connection with the appellant's participation in two tax shelters, Cowen Associates and Clay Properties. The Tax Court held that a...

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