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CRUTTENDEN v. C. I. R.

No. 79-7066.

644 F.2d 1368 (1981)

Walter W. CRUTTENDEN and Fay T. Cruttenden, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided May 15, 1981.

Attorney(s) appearing for the Case

R. Russell Mather, Washington, D.C., argued for respondent-appellant; Gilbert E. Andrews, Chief, Washington, D.C., on brief.

Lewis M. Porter, Jr., Boodell, Sears, Sugrue, Giambalvo & Crowley, Chicago, Ill., for petitioners-appellees.

Before NELSON and CANBY, Circuit Judges, and LARSON, District Judge.

NELSON, Circuit Judge:

In this appeal we confront the ambivalent tax characteristics of a practice in the stock brokerage industry: the borrowing of securities by a brokerage firm under a subordination agreement that allows the firm to use the securities to meet its net capital requirements under stock exchange rules. While it is clear that legal title to the securities does not pass from the lender to the brokerage firm by terms of the agreement under review, we...

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