Court of Appeals for the Fourth Circuit June 23, 1997, 96-2266 (Hyman S. Zfass v. Commissioner of Internal Revenue)

Affirmed by published opinion. Judge MURNAGHAN wrote the opinion, in which Judge NIEMEYER and Judge FABER joined.

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OPINION

MURNAGHAN, Circuit Judge:

The Internal Revenue Service (“IRS”) determined that Hyman Zfass, Appellant, participated in a tax shelter which was solely tax motivated.