United States Sixth Circuit

Individual taxpayers were not "at risk" under 26 USC 465(b), with regard to a three-party sale-leaseback transaction between parent company and two of its subsidiaries, precluding loss deductions from an investment in a trust formed by one of the subsidiaries.

Appellate Information

• Decided 12/29/2000
• Published 12/29/2000

Judges

• Before GUY and MOORE, Circuit Judges;  DOWD, District Judge.

Court

• United States Sixth Circuit

Counsel

• For Appellant:
  
• James H. Stethem (argued and briefed), Rosenberg, Herfel, Stethem & Bender, James V. Magee, Jr., Cincinnati, OH, for Appellants.


• For Appellees:
  
• Marion E.M. Erickson (argued and briefed), Bruce R. Ellisen (briefed), Joan I. Oppenheimer, U.S. Department of Justice, Appellate Section, Washington, DC, for Appellee.