John W. Barnard & June W. Barnard, Earl D. Kay, Jr. & Nancy O. Kay, Joseph J. Allen & Jennene S. Allen v. Commissioner of Internal Revenue

MURNAGHAN, Circuit Judge:

Sixteen taxpayers (individuals or husband and wife) 1 involved in the same transactions designed to provide them with income “tax shelters” found their cases consolidated before the United States Tax Court. In a comprehensive opinion filed May 18, 1983, Judge Arthur L. Nims, III upheld the assessments of income tax deficiencies for the years involved (1975, 1976 and 1977) in the case of each of the taxpayers. Fox, et al. v. Commissioner of Inter nal Revenue, 80 T.C. 972 (1983). Three, John W. Barnard and June W. Barnard, Earl D. Kay, Jr. and Nancy O. Kay, and Joseph…