JACOBSON v. C.I.R.

No. 155, Docket 89-4057.

915 F.2d 832 (1990)

Harvey JACOBSON and Marcia Jacobson, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided October 5, 1990.


Attorney(s) appearing for the Case

Walter J. Rockler, Washington, D.C. (Richard L. Hubbard, Arnold & Porter, Washington, D.C., of counsel), for petitioners-appellants.

Charles Bricken, Atty., Tax Div., Dept. of Justice, Washington, D.C. (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, David English Carmack, Attys., Tax Div., Dept. of Justice, Washington, D.C., of counsel), for defendant-appellee.

Before NEWMAN, PRATT and MAHONEY, Circuit Judges.


MAHONEY, Circuit Judge:

Harvey and Marcia Jacobson1 appeal from an order and decision of the United States Tax Court, B. John Williams, Jr., Judge, entered February 2, 1989 that determined (1) a federal income tax deficiency for 1979 in the amount of $29,444, and (2) that the entire deficiency constituted a substantial underpayment attributable to a tax-motivated transaction for purposes of computing the interest payable with respect...

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