In re: CM HOLDINGS, INC.; Camelot Music, Inc.; G.M.G. Advertising and Grapevine Records and Tapes, Inc., Debtors
Internal Revenue Service
v.
CM Holdings, Inc.
CM Holdings, Inc., Appellant
United States Court of Appeals, Third Circuit.https://leagle.com/images/logo.png
Argued October 30, 2001.
Filed: August 16, 2002.
Attorney(s) appearing for the Case
Michael I. Saltzman, Esquire, Lawrence M. Hill, Esquire, White & Case, Myron Kirschbaum, Esquire (Argued), Howard Kleinhendler, Esquire, Kaye, Scholer, Fierman, Hays & Handler, New York, NY, Pauline K. Morgan, Esquire, Young, Conaway, Stargatt & Taylor, Wilmington, DE, for Appellant.
Bernard J. Long, Jr., Esquire, J. Michael Hines, Esquire, Paul R. Lang, Esquire, Leslie H. Wiesenfelder, Esquire, Mark E. Liniado, Esquire, Suzanne R. Garment, Esquire, Dow, Lohnes & Albertson, Jerome B. Libin, Esquire, Sutherland, Asbill & Brennan, Washington, D.C., for Amicus Curiae-Appellant.
Claire Fallon, Acting Assistant Attorney General, Robert W. Metzler, Esquire, Richard Farber, Esquire, Dennis M. Donohue, Esquire (Argued), United State Department of Justice, Tax Division, Alex E. Sadler, Esquire, United States Department of Justice, Washington, D.C., James D. Hill, Esquire, Internal Revenue Service, Office of Chief Counsel, Cincinnati, OH, for Appellee.
Before: SLOVITER, NYGAARD and AMBRO, Circuit Judges.
United States Court of Appeals, Third Circuit.
OPINION OF THE COURT
AMBRO, Circuit Judge.
Appellant CM Holdings, Inc., the parent company of Camelot Music, Inc.,1 challenges the District Court's holding that loading dividends used to fund insurance premiums for corporate-owned life insurance ("COLI") policies were shams in fact, and that the transactions as a whole lacked economic substance. We affirm, based on the latter reasoning...
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