Legal Opinion
David C. Enrici Marianne Enrici Lawrence H. Easterling Phyllis Easterling v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided March 26, 1987No. 86-7072PublishedCited by 57 opinions
1Per curiam
This appeal mainly involves the issue of whether the losses and fees from certain “forward straddles” are deductible. The Tax Court disallowed these deductions and assessed a negligence penalty because it held that the forward contracts were sham transactions. The particular facts are exhaustively detailed in the published opinion below. Forseth v. Commissioner, 85 T.C. 127 (1985). The Enriéis and the Easter-lings, taxpayer-petitioners before the Tax Court, appeal.
In essence, the Tax Court held that Interact, LMEI and LMEC were taking advisory fees and margin “deposits” from the taxpayers;…
2Cases cited7 opinions
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- 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
- Gerald J. Rapp and Mary H. Rapp v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Forseth v. CommissionerUnited States Tax Court · 1985
2 more not listed; retrieve them via the Exa API.
3Cited by57 opinions
- Freytag v. CommissionerUnited States Tax Court · 1987
- James E. Sochin v. Commissioner of Internal Revenue, Dennis S. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- 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
- Ewing v. CommissionerUnited States Tax Court · 1988
- Louis Buddy Yosha v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
52 more not listed; retrieve them via the Exa API.