Court of Appeals for the Fourth Circuit January 7, 1985, 84-1246 (Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal Revenue)

JAMES DICKSON PHILLIPS, Circuit Judge:

Rice’s Toyota World (Rice) appeals the Tax Court’s decision upholding the Commissioner’s disallowance of interest and depreciation deductions that Rice took on income tax returns filed for 1976, 1977 and 1978 on the basis that underlying sale and leaseback transactions were, for tax purposes, a sham.