RINK v. C.I.R.

No. 93-2362.

47 F.3d 168 (1995)

Thomas C. RINK and Alison W. Rink, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided February 16, 1995.


Attorney(s) appearing for the Case

Charles G. Atkins (briefed), Thomas C. Rink (argued and briefed), Strauss & Troy, Cincinnati, OH, for petitioners-appellants.

Ann Belanger Durney, Alice L. Ronk (argued), Gary R. Allen, Acting Chief (briefed), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, DC, James D. Hill, Cincinnati, OH, for respondent-appellee.

Before: MILBURN and SUHRHEINRICH, Circuit Judges; and JOINER, District Judge.


SUHRHEINRICH, Circuit Judge.

This appeal presents two issues: 1) whether the tax court's interpretation of the Closing Agreement entered by taxpayers and the Internal Revenue Service ("IRS") was erroneous; and 2) whether the tax court erred in finding that a 1986 lease was without substance for tax purposes.1 For the reasons that follow, we AFFIRM.

I.

The relevant facts to this appeal are as follows. Petitioner...

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