COLE v. C.I.R.

No. 10-2194.

637 F.3d 767 (2011)

Scott C. COLE and Jennifer A. Cole, Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided March 28, 2011.


Attorney(s) appearing for the Case

Scott C. Cole (argued), Brownsburg, IN, pro se.

Jennifer A. Cole , Brownsburg, IN, pro se.

Bruce R. Ellisen , Damon Taaffe (argued), Attorneys, Department of Justice, William J. Wilkins , Attorney, Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before KANNE, TINDER, and HAMILTON, Circuit Judges.


TINDER, Circuit Judge.

Appellants Scott C. and Jennifer A. Cole (a married couple from Brownsburg, Indiana) ran into trouble with the Internal Revenue Service (IRS) in 2003, when a revenue agent began auditing their 2001 joint tax return. Through this audit, the agent discovered a web of corporate and partnership entities serving dubious purposes, undocumented financial transactions, and inconsistent reports regarding the Coles' income. Incongruously, although Scott...

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