United States Fourth Circuit

Taxpayers may not legally deduct their passive management fee expenses from their related nonpassive management fee income for purposes of lowering their taxable income.

Appellate Information

• Argued 02/28/2001
• Decided 07/30/2001
• Published 07/30/2001

Judges

• Before WILKINS and WILLIAMS, Circuit Judges, and HAMILTON, Senior Circuit Judge.

Court

• United States Fourth Circuit

Counsel

• For Appellees:
  
• ARGUED:  Kenneth L. Greene, Tax Division, United States Department of Justice, Washington, DC, for Appellant.  Stefan F. Tucker, Venable, Baetjer, Howard & Civiletti, L.L.P., Washington, DC, for Appellees.   ON BRIEF:  Paula M. Junghans, Acting Assistant Attorney General, Howard T. Perelmuter, Tax Division, United States Department of Justice, Washington, DC, for Appellant.  David E. Sellinger, Susan Edlavitch, Damon W.D. Wright, Venable, Baetjer, Howard & Civiletti, L.L.P., Washington, DC, for Appellees.