Gerald Leuhsler, Beverly Leuhsler v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
RYAN, Circuit Judge.
Gerald and Beverly Leuhsler appeal a decision of the Tax Court upholding the Commissioner of Internal Revenue’s imposition of negligence and valuation overstatement penalties. 1 26 U.S.C. §§ 6653, 6659. We affirm.
I
Gerald Leuhsler holds a bachelor of science degree in accounting and is employed as a certified public accountant at Forest City Enterprises, a real estate development company in Cleveland, Ohio. In late 1981, Leuhsler and several coworkers at Forest City Enterprises and friends were presented with an investment opportunity promising tax savings that were at…
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