Legal Opinion
Kerry W. Illes v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided September 21, 1992No. 91-2412PublishedCited by 88 opinions
1Per curiam
Taxpayer Kerry W. Ules appeals from the Tax Court’s determination that he is liable for deficiencies and penalties as a result of his investment in a tax shelter that lacked economic substance. We AFFIRM.
I
During 1984 and 1985, Structured Shelters, Inc. (“SSI”) through its agent Thomas A. Graham, marketed a product called Children’s Classics Audio Cassettes (“CCAC”). The CCAC promotion had two phases, a production phase and a lease phase. The 1985 production phase involved the purchase of the right to reproduce artwork and to use titles for the products of new master cassette recordings from…
2Cases cited13 opinions
- James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- William S. Skeen and Alison Skeen v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
8 more not listed; retrieve them via the Exa API.
3Cited by88 opinions
- Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Glenn A. Mortensen v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Hyman S. Zfass v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1997
83 more not listed; retrieve them via the Exa API.