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NAPOLIELLO v. C.I.R.

No. 09-72389.

655 F.3d 1060 (2011)

Michael E. NAPOLIELLO, Petitioner, v. COMMISSIONER of INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Filed August 23, 2011.

Attorney(s) appearing for the Case

Edward Robbins , Hochman, Salkin, Rettig, Tocher & Perez, P.C., Beverly Hills, California, for the petitioner.

Joan Oppenheimer , Department of Justice, Washington, DC, for the respondent.

Before: JOHN T. NOONAN and KIM McLANE WARDLAW, Circuit Judges, and EDWARD R. KORMAN, Senior District Judge.

OPINION

NOONAN, Circuit Judge:

Michael Napoliello appeals the United States Tax Court's decision in favor of the Commissioner of Internal Revenue. We have jurisdiction under 26 U.S.C. § 7482(a), and we affirm.

FACTS

This case arises from the Internal Revenue Service's ("IRS") investigation of a tax shelter. The type of shelter is known as a "Son-of-BOSS" (being a variant of the Bond and Options...

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