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ZFASS v. C.I.R.

No. 96-2266.

118 F.3d 184 (1997)

Hyman S. ZFASS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided June 23, 1997.

Attorney(s) appearing for the Case

ARGUED: Craig Dennis Bell, Taylor, Hazen & Kauffman, L.C., Richmond, VA, for appellant. Patricia McDonald Bowman, Tax Division, United States Department of Justice, Washington, DC, for appellee. ON BRIEF: Loretta C. Argrett, Assistant Attorney General, Richard Farber, Tax Division, United States Department of Justice, Washington, DC, for appellee.

Before MURNAGHAN and NIEMEYER, Circuit Judges, and FABER, United States District Judge for the Southern District of West Virginia, sitting by designation.

Affirmed by published opinion. Judge MURNAGHAN wrote the opinion, in which Judge NIEMEYER and Judge FABER joined.

OPINION

MURNAGHAN, Circuit Judge:

The Internal Revenue Service ("IRS") determined that Hyman Zfass, Appellant, participated in a tax shelter which was solely tax motivated. The IRS, therefore, disallowed the deductions taken on his income tax returns and required him to pay interest and...

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