LANDRETH v. C.I.R.

Nos. 86-7588, 86-7636.

845 F.2d 828 (1988)

Ivan K. LANDRETH; Lucille Landreth, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 26, 1988.


Attorney(s) appearing for the Case

Robert J. Shaw, Short & Cressman, Seattle, Wash., for petitioners-appellants.

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

David D. Aughtry, Atlanta, Ga., for amicus curiae I.C. Hemmings.

Before FLETCHER and NORRIS, Circuit Judges, and MacBRIDE, District Judge.


NORRIS, Circuit Judge:

I

The principal issue in this case is whether the Landreths (taxpayers) can deduct losses from commodity futures "straddles,"1 incurred in 1978, if their primary motive for entering into those straddle transactions was to create tax losses rather than to realize a profit. Unless engaged in a trade or business, taxpayers can deduct losses from straddle transactions only if the losses are "incurred in a transaction...

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