William T. And Lynne L. Wright W-T-W, Inc. D/B/A Totem Lake Ford/toyota Bill Wright Toyota, Inc. v. Commissioner of Internal Revenue

73 F.3d 372 76 A.F.T.R.2d 95 -8096, 96-1 USTC P 50,086 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. William T. and Lynne L. WRIGHT; W-T-W, Inc.; d/b/a Totem Lake Ford/Toyota; Bill Wright Toyota, Inc., Petitioners/Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent/Appellee. Nos. 94-70283, 94-70358. United States Court of Appeals, Ninth Circuit. Argued and Submitted Aug. 7, 1995. Decided Dec. 20, 1995. Before: BROWNING, NORRIS, and REINHARDT, Circuit Judges. 1 ORDER * 2 The appellants' motion to certify materials for additional excerpts of record is DENIED. 3 Appellants challenge the following findings of fact by the Tax Court, which we review under the clearly erroneous standard: 1 (1) that First Interstate Re, Inc. ("FIR") was a sham corporation formed for the purpose of avoiding taxes on income earned by appellant William T. Wright or by automobile dealerships owned by Wright; (2) that the understatements of income on Wright's tax returns for the years 1983,…