Legal Opinion
Lerman v. Commissioner
Court of Appeals for the Third Circuit
Decided July 17, 1991No. Nos. 90-1813 to 90-1815 and 90-1835 to 90-1837PublishedCited by 35 opinions
1Opinion of the Court
OPINION OF THE COURT
GREENBERG, Circuit Judge.
Introduction
This case involves the continuing saga of a crackdown by the Commissioner of Internal Revenue on a tax shelter device we will call the “option-straddle transaction” and the divers attempts of various taxpayers to avoid the consequences of this crackdown.
The particular straddle transactions involved silver options on the London Metals Exchange. Appellant-taxpayers, Charles S. Lerman, Joseph L. Fraites, and Dwight B. Massey, who on this appeal are assumed to be commodities dealers, engaged in the transactions on the Exchange, and deducted…
2Cases cited28 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
23 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Connecticut General Life Insurance Company v. Commissioner of Internal Revenue (Tax Court No. 92-21212). Cigna Corporation and Consolidated Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 92-21213)Court of Appeals for the Third Circuit · 1999
- Armstrong World Industries, Inc., and Affiliated Companies v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1992
- Tate & Lyle, Inc. And Subsidiaries v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1996
- Jay Graffen Cass Graffen v. City of Philadelphia, Jay & Cass GraffenCourt of Appeals for the Third Circuit · 1992
30 more not listed; retrieve them via the Exa API.