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CAHN v. C.I.R.

Nos. 19417, 19418.

358 F.2d 492 (1966)

Sammy CAHN and Gloria Cahn, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

April 4, 1966.

Attorney(s) appearing for the Case

Hilbert P. Zarky, Irving I. Axelrad, Edward R. McHale, of Mitchell, Silberberg & Knupp, Los Angeles, Cal., for petitioners.

Louis P. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson, Jeanine Jacobs, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before CHAMBERS and BARNES, Circuit Judges, and FOLEY, Jr., District Judge.

BARNES, Circuit Judge:

These are petitions to review an opinion of the Tax Court which affirmed the determination of deficiencies in both of the taxpayers' returns for the year 1957. Involved is another variant of the oft-litigated plan for reducing income taxes by deductions for the alleged payment of interest on loans to finance security purchases. The plan, devised by the self-styled Boston financier, M. Eli Livingstone, has been consistently rejected by the courts...

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