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SOCHIN v. C.I.R.

Nos. 87-7024, 87-7032.

843 F.2d 351 (1988)

James E. SOCHIN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Dennis S. BROWN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided March 29, 1988.

Attorney(s) appearing for the Case

Joseph Wetzel, Wetzel & DeFrang, Portland, Or., for petitioners-appellants.

Michael C. Durney, Acting Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before CHOY, GOODWIN and BEEZER, Circuit Judges.

CHOY, Circuit Judge:

James Sochin and Dennis Brown ("Taxpayers") appeal from the tax court's deficiency determinations. The court disallowed the losses and expenses deducted by Taxpayers with respect to investments in straddle transactions involving forward contracts. The court held that the transactions were "factual shams." Brown v. Commissioner, 85 T.C. 968, 998-1000 (1985). On appeal, Taxpayers allege that the tax court:...

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