Stephen Pledger (99-4254) Marcia G. Pledger(99-4276) v. United States
Court of Appeals for the Sixth Circuit
1Opinion of the Court
OPINION
MOORE, Circuit Judge.
This case involves the question of whether individual taxpayers were “at risk,” as defined in 26 U.S.C. § 465(b), with regard to a three-party sale-leaseback transaction between a parent company and two of its subsidiaries and could therefore deduct losses from an investment in a trust formed by one of the subsidiaries. In the tax years ending in 1985, 1986, 1987, and 1988, Plaintiffs-Appellants, Stephen (“Pledger”) and Marcia Pledger (“Mrs. Pledger”) (collectively referred to as “the Pledgers”), claimed losses deriving from Pledger’s investment in a trust under §…
2Cases cited12 opinions
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Billy v. Consolidated Machine Tool Corp.New York Court of Appeals · 1980
- Porter v. LSB Industries, Inc.Appellate Division of the Supreme Court of the State of New York · 1993
- American Principals Leasing Corp. v. United StatesCourt of Appeals for the Ninth Circuit · 1990
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