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BLUM v. C.I.R.

No. 12-9005.

737 F.3d 1303 (2013)

Scott A. BLUM; Audrey R. Blum, Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

December 18, 2013.

Attorney(s) appearing for the Case

Christopher Reimer of Long Reimer Winegar Beppler, LLP, Jackson, Wyoming, for Appellants.

Judith Hagley of the U.S. Department of Justice, Tax Division, Appellate Section, ( Kathryn Keneally , Assistant Attorney General; Tamara W. Ashford , Deputy Assistant Attorney General; Gilbert S. Rothenberg , Attorney; Richard Farber , Attorney, Department of Justice, with her on the brief) Washington, DC, for Appellee.

Before HARTZ and TYMKOVICH, Circuit Judges, and JACKSON, District Judge.

JACKSON, District Judge.

I. Introduction

This case comes to us on appeal from a decision of the Tax Court upholding the actions of the Commissioner of the Internal Revenue Service (IRS) invalidating a financial transaction as lacking economic substance and imposing two accuracy-related penalties for underpayment of taxes. We have jurisdiction to hear this appeal under I.R.C. § 7482(a)(1). The intricacies of this offshore financial transaction and the...

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