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KERMAN v. C.I.R.

No. 11-1822.

713 F.3d 849 (2013)

Mark L. KERMAN and Lucy M. Kerman, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: April 8, 2013.

Attorney(s) appearing for the Case

ARGUED: Donald L. Cox , Lynch, Cox, Gilman & Goodman, PSC, Louisville, Kentucky, for Appellants. Judith A. Hagley , United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Donald L. Cox , Clare Feler Cox , Matthew D. Watkins , Lynch, Cox, Gilman & Goodman, PSC, Louisville, Kentucky, for Appellants. Judith A. Hagley , Tamara W. Ashford , Gilbert S. Rothenberg , Richard Farber , United States Department of Justice, Washington, D.C., for Appellee.

Before: KETHLEDGE and WHITE, Circuit Judges; LUDINGTON, District Judge.

OPINION

LUDINGTON, District Judge.

A tax shelter can be legitimate — if the reported transaction has economic substance. But the shelter Mark Kerman participated in lacked such substance. The transaction had no purpose other than the creation of an income tax benefit. After Kerman claimed the benefit on his tax return, the IRS disallowed the deduction and imposed a valuation misstatement penalty pursuant to 26 U.S.C. § 6662(e), which was increased...

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