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WOLF v. C.I.R.

No. 91-70694.

4 F.3d 709 (1993)

August C. WOLF; Muriel M. Wolf, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided August 27, 1993.

Attorney(s) appearing for the Case

Henry D. Nunez, Fresno, CA, for petitioners-appellants.

Joan I. Oppenheimer, Tax Div., U.S. Dept. of Justice, Washington, DC, for respondent-appellee.

Before: WALLACE, Chief Judge, O'SCANNLAIN and FERNANDEZ, Circuit Judges.

WALLACE, Chief Judge:

The Internal Revenue Service (IRS) challenged the returns of numerous taxpayers who invested in a tax shelter marketed by Encore Leasing Corporation (Encore). One of them, Wolf, appeals from a decision of the tax court upholding the IRS's disallowance of several deductions on Wolf's 1979-1982 federal income tax returns and affirming the IRS's assessment of additions to tax and penalties. The tax court exercised jurisdiction

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