Legal Opinion
Howard Ratliff and Gloria Ratliff v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided January 6, 1989No. 88-1191PublishedCited by 41 opinions
1Opinion of the Court
MILBURN, Circuit Judge.
The present case is but one part of the London option cases pending in the United States Courts of Appeals around the country after the decision of the Tax Court in Glass v. Commissioner, 87 T.C. 1087 (1986). In Glass, the Tax Court consolidated over 1,100 petitions contesting the decision of the Commissioner of Internal Revenue that losses sustained in connection with certain straddle transactions on the London Metal Exchange were not deductible because the transactions, among other things, “lacked economic substance and [were] a sham.” Glass, 87 T.C. at 1177 (relying…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Glass v. CommissionerUnited States Tax Court · 1986
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
9 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- David Dewees and Anne Dewees v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1989
- Halpern v. CommissionerUnited States Tax Court · 1991
- Terence J. Horn and Jean Horn v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Terence J. Horn and Jean HornCourt of Appeals for the D.C. Circuit · 1992
- The Dow Chemical Company v. United StatesCourt of Appeals for the Sixth Circuit · 2006
- Dean B. Smith and Irma Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1991
36 more not listed; retrieve them via the Exa API.