Ernest J. Saviano and Margaret Saviano v. Commissioner of Internal Revenue

WILLIAM J. CAMPBELL, Senior District Judge.

“Gold for Tax Dollars,” certainly an alluring phrase, is the title of a tax shelter that has enticed thousands of taxpayers with dreams of large deductions. The plan contemplated the taxpayer investing in a gold mine in Panama (for taxable year 1978) or French Guiana (for taxable year 1979) and obtaining thereby a tax deduction equivalent to four times the actual investment. However, the Commissioner of Internal Revenue Service, concluding that the shelter resulted in precious few tax dollars and precious little gold, has disallowed certain of the…