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| Third Circuit: Camelot Music's COLI Arrangement Lacked Economic Substance (PDF) U.S. Court of Appeals for the Third Circuit, via FindLaw  [Opinion] Aug. 19, 2002 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[.] |
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