John B. Riederich Carole M. Riederich v. Commissioner Internal Revenue Service

985 F.2d 574 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. John B. RIEDERICH; Carole M. Riederich, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70502. United States Court of Appeals, Ninth Circuit. Argued and Submitted Feb. 4, 1993. Decided Feb. 8, 1993. Appeal from a Decision of the United States Tax Court; No. 14357-86. AFFIRMED. Before PREGERSON, LEAVY and TROTT, Circuit Judges. 1 MEMORANDUM * 2 John and Carole Riederich ("Taxpayers") took a $19,900 tax credit against their federal personal income taxes for 1979, 1980, and 1982 as the result of their investment of $13,000 in the so-called Entertainment Marketing Company, Incorporated ("EMCI") master tape leasing program, a sham tax shelter. The Internal Revenue Service ("IRS") disallowed the credit and assessed Taxpayers not only for the unpaid taxes but for additional interest, late fees, and penalties as well. Taxpayers conceded their liability for the unpaid taxes…