Legal Opinion
John J. Waters and Jeanne M. Waters v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided October 21, 1992No. 1512, Docket 92-4023PublishedCited by 25 opinions
1Opinion of the Court
MAHONEY, Circuit Judge:
John J. and Jeanne M. Waters appeal from a decision of the United States Tax Court, Stephen J. Swift, Judge, which ruled, inter alia, that John Waters (“Waters”) was protected against loss, and therefore not “at risk” within the meaning of § 465 of the Internal Revenue Code of 1954, 1 with respect to a nominally recourse note executed in connection with his investment in the purchase and lease of peripheral computer equipment. Waters v. Commissioner, 62 T.C.M. (CCH) 778 (1991).
We affirm.
Background
John J. and Jeanne M. Waters, husband and wife, filed joint federal income…
2Cases cited18 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Blum v. StensonSupreme Court of the United States · 1984
- Toibb v. RadloffSupreme Court of the United States · 1991
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- Rose v. CommissionerUnited States Tax Court · 1987
13 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Pierpoint v. BarnesCourt of Appeals for the Second Circuit · 1996
- Isaac Baranowicz v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2005
- Levien v. CommissionerUnited States Tax Court · 1994
- Charles E. Nicholson, Jr. And Margaret K. Nicholson v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1995
- James v. Martuccio Louise A. Martuccio v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1994
20 more not listed; retrieve them via the Exa API.