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MAHONEY v. C.I.R.

No. 86-1131.

808 F.2d 1219 (1987)

Stephen A. MAHONEY, III, and Mary Ann Mahoney, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided January 14, 1987.

Attorney(s) appearing for the Case

Fred T. Goldberg, Chief Counsel, Internal Revenue Service, Washington, D.C., W. Jere Blackshere, Asst. Dist. Counsel, Dallas, Tex., Michael L. Paup, Dept. of Justice, Tax Div., Washington, D.C., Roger M. Olsen, Richard Farber, Kenneth L. Greene (argued), for respondent-appellee.

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

Before WELLFORD and GUY, Circuit Judges; and PECK, Senior Circuit Judge.

RALPH B. GUY, Jr., Circuit Judge.

This is a complicated case involving gold and platinum straddles on the London market. Although we are dealing with only one appellant, the case was actually a consolidated trial at the Tax Court level, involving several different persons similarly situated.

The issue in the case is the deductibility of the tax losses sustained by all the taxpayers who entered into these straddles. Such transactions, in order to be deductible...

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