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SMITH v. C.I.R.

No. 90-1007.

937 F.2d 1089 (1991)

Dean B. SMITH and Irma Smith, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided June 27, 1991.

Attorney(s) appearing for the Case

Dennis N. Brager (argued), Jackson D. Hamilton, Spensley, Horn, Jubas & Lubitz, Los Angeles, Cal., for petitioners-appellants.

Peter K. Scott, I.R.S., Office of Chief Counsel, Gary R. Allen, Acting Chief, Mary F. Clark, David I. Pincus (argued), Kenneth W. Rosenberg, U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for respondent-appellee.

Before NELSON, Circuit Judge, WELLFORD, Senior Circuit Judge, and JOINER, Senior District Judge.

WELLFORD, Senior Circuit Judge.

Appellants, Dean B. Smith and Irma Smith, appeal from the decision of the United States Tax Court concerning deficiencies and penalties imposed upon their federal income tax for 1981 and 1982 by the Commissioner of Internal Revenue. The Tax Court determined that the 1981 and 1982 deficiencies constituted substantial underpayments attributed to a tax-motivated transaction under I.R.C. § 6621 and that petitioners were liable for...

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