SUHRHEINRICH, J., delivered the opinion of the court, in which SILER, J., joined. BOGGS, J. (pp. 834-35), delivered a separate opinion concurring in the result.
SUHRHEINRICH, Circuit Judge.
This case involves the tax consequences of an investment in sham transactions by a taxpayer. We must decide whether the taxpayer is entitled to a refund of deficiencies and penalties paid. We must also determine whether the interest penalty imposed by I.R.C. § 6621...
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