Albert E. King Geraldine King, Wife v. United States of America and It's Internal Revenue Service

KLEINFELD, Circuit Judge:

This is a tax case involving whether a forfeiture of drug money is deductible.

Facts.

This case was decided on cross motions for summary judgment, so we set out the facts based on the affidavits and other materials submitted on the motions.

Albert. King operated a ranch for his family partnership. He allowed others to grow marijuana on the ranch, and was paid for it. When he got caught, in a raid on the ranch pursuant to a search warrant, he cooperated fully with the government. Ultimately King and the - government made a plea bargain pursuant to which King would get a…