KARR v. C.I.R.

No. 90-8000.

924 F.2d 1018 (1991)

James KARR and Nancy L. Karr, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eleventh Circuit.

February 27, 1991.


Attorney(s) appearing for the Case

Dennis N. Brager, Jackson D. Hamilton, Spensley, Horn, Jubas & Lubitz, Los Angeles, Cal., for petitioners.

Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, Chief, Appellate Section, Kenneth W. Rosenberg, Mary Frances Clark and David I. Pincus, Tax Div., Dept. of Justice, Washington, D.C., for respondent.

Before JOHNSON and HATCHETT, Circuit Judges, and DYER, Senior Circuit Judge.


HATCHETT, Circuit Judge:

In this tax case, we affirm the Tax Court holding that the transactions in question constituted sham transactions, subjecting the taxpayers to deficiencies, additions to taxes, and interest.

FACTS

Richard Basile was a promoter of energy-related limited partnerships. In 1981, he discussed a possible K-Fuel project with a Swiss investor, with whom Basile had an ongoing relationship. K-Fuel is a dry, stable, high heating value...

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