Legal Opinion

Stephen Pledger (99-4254) Marcia G. Pledger(99-4276) v. United States

Court of Appeals for the Sixth Circuit

Decided December 29, 2000No. 99-4254, 99-4276PublishedCited by 9 opinions

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

  1. Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
  2. Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
  3. Billy v. Consolidated Machine Tool Corp.New York Court of Appeals · 1980
  4. Porter v. LSB Industries, Inc.Appellate Division of the Supreme Court of the State of New York · 1993
  5. American Principals Leasing Corp. v. United StatesCourt of Appeals for the Ninth Circuit · 1990

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3Cited by9 opinions

  1. Larry Lee v. Dean WilleyCourt of Appeals for the Sixth Circuit · 2015
  2. Ohio State Conference of the National Ass'n v. HustedCourt of Appeals for the Sixth Circuit · 2014
  3. United States v. Donald Lynn BaggettCourt of Appeals for the Sixth Circuit · 2003
  4. United States v. John A. Rapanos Judith A. Nelkie Rapanos Prodo, Inc. Rolling Meadows Hunt Club Pine River Bluff Estates, Inc.Court of Appeals for the Sixth Circuit · 2004
  5. Taverns for Tots, Inc. v. City of ToledoDistrict Court, N.D. Ohio · 2004

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