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SAMUELI v. C.I.R.

Nos. 09-72457, 09-72458.

658 F.3d 992 (2011)

Henry SAMUELI; Susan F. Samueli, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Patricia W. Ricks; Thomas G. Ricks, Petitioners-Appellants, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed September 15, 2011.

Attorney(s) appearing for the Case

Richard M. Lipton , Baker & McKenzie, Chicago, IL, for the petitioners-appellants.

Bethany B. Hauser , Tax Division, U.S. Department of Justice, Washington, DC, for the respondent-appellee.

Opinion by Judge TASHIMA; Concurrence by Judge RAWLINSON.

OPINION

TASHIMA, Circuit Judge:

This case requires us to decide whether a purported securities loan with a fixed term of at least 250 days and possibly as long as 450 days, entered into not for the purpose of providing the borrower with access to the lent securities, but instead for the purpose of avoiding taxable income for the lender, qualifies for nonrecognition treatment as a securities loan pursuant to § 1058 of the Internal Revenue Code (the ...

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