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BARTON v. C.I.R.

No. 88-8844.

893 F.2d 306 (1990)

Walter F. BARTON and Betty E. Barton, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eleventh Circuit.

Rehearing Denied June 11, 1990.

Attorney(s) appearing for the Case

Roger A. Pies, Morgan, Lewis & Bockius, Washington, D.C., for petitioners.

Gary R. Allen, Chief, William S. Rose, Jr., William S. Estabrook, Charles Bricken, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., for respondent.

Before CLARK and EDMONDSON, Circuit Judges, and TUTTLE, Senior Circuit Judge.

CLARK, Circuit Judge:

In this appeal from the United States Tax Court, we are asked to untangle a complicated "sale/lease-back" transaction to determine whether, during 1982, the appellants were "at risk" within the meaning of Section 465(b) of the Internal Revenue Code of 1954, as amended. Based on a stipulated factual record, the Tax Court found that the appellants were not at risk and upheld the Commissioner's deficiency assessment. Having extensively analyzed...

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