Court of Appeals for the Sixth Circuit February 16, 1995, 93-2362 (Thomas C. Rink and Alison W. Rink v. Commissioner of Internal Revenue)

SUHRHEINRICH, Circuit Judge.

This appeal presents two issues: 1) whether the tax court’s interpretation of the Closing Agreement entered by taxpayers and the Internal Revenue Service (“IRS”) was erroneous; and 2) whether the tax court erred in finding that a 1986 lease was without substance for tax purposes.

1

For the reasons that follow, we AFFIRM.

I.

The relevant facts to this appeal are.