William E. Bailey v. Commissioner of Internal Revenue

KRUPANSKY, Circuit Judge.

Taxpayer William E. Bailey (Bailey) appeals from an order of the tax court granting summary judgment in favor of the Commissioner and holding that taxpayer is not entitled to the benefits of the remedial provisions of § 1341 of the Internal Revenue Code (I.R.C.).

Bailey was an officer, shareholder and director of Bestline Products, Inc., and Bestline Products Corporation (Bestline), a “pyramid” multi-level direct sales organization. Bailey received salary, dividends and bonuses from Bestline in his capacity as an officer, shareholder and director and included such…