ILLES v. C.I.R.

No. 91-2412.

982 F.2d 163 (1992)

Kerry W. ILLES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided September 21, 1992.


Attorney(s) appearing for the Case

Mark E. Gammons (argued and briefed), Rocky River, OH, Robert J. Fedor, Rocky River, OH, for petitioner-appellant.

Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S., Office of Chief Counsel, Gary R. Allen, Acting Chief (briefed) Doris D. Coles, Bruce R. Ellisen, Janice B. Geier (argued), U.S. Dept. of Justice, Appellate Section Tax Div., DC, for respondent-appellee.

Before: NELSON, NORRIS, and SUHRHEINRICH, Circuit Judges.


PER CURIAM.

Taxpayer Kerry W. Illes appeals from the Tax Court's determination that he is liable for deficiencies and penalties as a result of his investment in a tax shelter that lacked economic substance. We AFFIRM.

I.

During 1984 and 1985, Structured Shelters, Inc. ("SSI") through its agent Thomas A. Graham, marketed a product called Children's Classics Audio Cassettes ("CCAC"). The CCAC promotion had two phases, a production phase and a lease...

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