IRS v. CM Holdings, Inc., No. 00-3875 (3d Circuit Aug. 16, 2002). Excerpt: Appellant CM Holdings, Inc. ("CM Holdings'), the parent company of Camelot Music, Inc. ('Camelot'), challenges the District Court's holding that loading dividends used to fund insurance premiums for corporate-owned life insurance ('COLI") policies were shams in fact, and that the transactions as a whole lacked economic substance. We affirm[.]