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ENRICI v. C.I.R. SERVICE

No. 86-7072.

813 F.2d 293 (1987)

David C. ENRICI; Marianne Enrici; Lawrence H. Easterling; Phyllis Easterling, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 26, 1987.

Attorney(s) appearing for the Case

Larry K. Hercules and Edward G. Lavery, Dallas, Tex., for petitioners-appellants.

Kenneth L. Greene, Washington, D.C., for respondent-appellee.

Before PREGERSON and NORRIS, Circuit Judges, and BURNS, District Judge.

PER CURIAM:

This appeal mainly involves the issue of whether the losses and fees from certain "forward straddles" are deductible. The Tax Court disallowed these deductions and assessed a negligence penalty because it held that the forward contracts were sham transactions. The particular facts are exhaustively detailed in the published opinion below. Forseth v. Commissioner, 85 T.C. 127 (1985). The Enricis and the Easterlings...

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