Legal Opinion
James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided March 29, 1988No. 87-7024, 87-7032PublishedCited by 141 opinions
1Opinion of the Court
CHOY, Circuit Judge:
James Sochin and Dennis Brown (“Taxpayers”) appeal from the tax court’s deficiency determinations. The court disallowed the losses and expenses deducted by Taxpayers with respect to investments in straddle transactions involving forward contracts. The court held that the transactions were “factual shams.” Brown v. Commissioner, 85 T.C. 968, 998-1000 (1985). On appeal, Taxpayers allege that the tax court: 1) failed to apply the proper legal standard for determining what a sham is; 2) failed to make adequate factual findings as required by 26 U.S.C. § 7459(b); 3) improperly…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- George A. Lies v. Farrell Lines, Inc. And Does One Through Ten, InclusiveCourt of Appeals for the Ninth Circuit · 1981
- Alan B. Karme and Laila M. Karme v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Erik Unt v. The Aerospace Corporation, United States Air Force, Space and Missile Systems Organization, and Air Force Systems CommandCourt of Appeals for the Ninth Circuit · 1985
- Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
13 more not listed; retrieve them via the Exa API.
3Cited by141 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- McCrary v. CommissionerUnited States Tax Court · 1989
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Kenneth P. Kirchman and Budagail S. Kirchman, Leo P. Ayotte and Nancy C. Ayotte v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1989
136 more not listed; retrieve them via the Exa API.