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POLAKOF v. C.I.R.

Nos. 85-7581 to 85-7583, 85-7585 to 85-7587, 86-7312.

820 F.2d 321 (1987)

James POLAKOF, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Roy C. PETERSON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Lee E. SCHWARTZ and Vera J. Schwartz, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Roman J. and Lorraine A. OLEYNIK, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. David and Frances STEVENSON, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Arlin BLACKWELL and Sharon Blackwell, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Clarence H. STEINHEBEL; Gertrude Steinhebel; Michael A. Baker; Sue B. Baker; Leonard A. Vinci; Ken B. Teakle; Marilyn L. Teakle; John Ferreri; June Ferreri; Dean S. Merrick; Marilyn Merrick; Francis X. Driscoll; Patricia B. Driscoll, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 22, 1987.

As Amended June 30, 1987.

Attorney(s) appearing for the Case

John Gigounas and Edward B. Simpson, San Francisco, Cal., for petitioner-appellant.

Michael L. Paup and Theresa McLaughlin, Washington, D.C., for respondent-appellee.

Before WALLACE, SKOPIL and CANBY, Circuit Judges.

PER CURIAM:

Petitioners are limited partners in one or more partnerships organized by Cinema Financial of America, Inc. (CFA) as general partner. The limited partnerships acquired feature-length motion pictures from CFA for distribution. Early investor tax benefits were a major selling point in CFA's offerings for partnership interests; acquisition was financed through large nonrecourse notes payable from a percentage of...

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