United States Ninth Circuit

In an appeal from a tax deficiency determination by the tax court, judgment is affirmed where a purported securities loan entered into not for the purpose of providing the borrower with access to the lent securities, but for the purpose of avoiding taxable income for the lender, does not qualify for nonrecognition treatment as a securities loan pursuant to 26 U.S.C. section 1058.

Appellate Information

• Decided 09/15/2011
• Published 09/15/2011

Judges

• TASHIMA

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Richard M. Lipton, Bethany B. Hauser