Legal Opinion
Kenneth P. Kirchman and Budagail S. Kirchman, Leo P. Ayotte and Nancy C. Ayotte v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided January 11, 1989No. 87-3585PublishedCited by 109 opinions
1Opinion of the Court
JOHNSON, Circuit Judge:
This case arises on appeal from a United States Tax Court decision affirming the Commissioner of the I.R.S. in assessing a deficiency against appellant taxpayers. The Commissioner assessed a deficiency against approximately 1400 taxpayers for loss deductions taken for years 1975 through 1980 incurred in connection with commodity transactions entered into on the London Metals Exchange. Taxpayers’ challenges were consolidated in a single case before the tax court. The tax court held that these transactions were shams with no legitimate economic substance because taxpayers…
2Cases cited25 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Murray Stein v. Reynolds Securities, Inc.Court of Appeals for the Eleventh Circuit · 1982
- 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
20 more not listed; retrieve them via the Exa API.
3Cited by109 opinions
- United States v. Monroe Adlman, as Officer and Representative of Sequa CorporationCourt of Appeals for the Second Circuit · 1998
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- 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
- Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
104 more not listed; retrieve them via the Exa API.