New Phoenix Sunrise Corp., et al. v. Comr., 408 Fed. Appx. 908 (6th Cir. 2010), aff'g 132 T.C. 161 (2009)

(Tax Court decision (132 T.C. No. 9 (2009) affirmed; taxpayer, a corporation involved in the ag industry who manufactured plastic bags, had tax deficiency and penalties of approximately $4.5 million based on losses claimed from two swap contracts that caused economic loss of just over $100,000; transaction lacked economic substance; case involves Jenken’s and Gilchrist tax shelter).