Robert S. YOUNG and Kimberly C. Young, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Osvaldo DIAZ and Zoraida Diaz, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Jorge EGURROLA, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Ann WILSON, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
John L. WILSON, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Osvaldo DIAZ, M.D., P.A., Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Steven GOLD, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Harold GOLD and Helen Gold, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Thomas O. GENTSCH and Betty F. Gentsch, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Edward ROSENGARTEN and Katherine Rosengarten, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
Allen J. COHEN and Dorothy E. Cohen, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Eleventh Circuit.https://leagle.com/images/logo.png
March 19, 1991.
March 19, 1991.
Attorney(s) appearing for the Case
Robert S. Lamont, Neiman & Feuerman, P.A., Jan S. Neiman, Miami, Fla., for petitioners-appellants and No. 89-6231.
Theodore F. Brill, Planation, Fla., for petitioners-appellants and No. 89-6213.
Steven S. Brown, Leigh D. Roadman, Silets & Martin, Chicago, Ill., for petitioners-appellants and No. 89-6246.
Peter K. Scott, Acting Chief Counsel, IRS, Shirley D. Peterson, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Gary R. Allen, Chief, Joan I. Oppenheimer, Brian C. Griffin, David I. Pincus, Appellate Section, Tax Div., Washington, D.C., for respondent-appellee.
Before TJOFLAT, Chief Judge, EDMONDSON, Circuit Judge, and DYER, Senior Circuit Judge.
United States Court of Appeals, Eleventh Circuit.
DYER, Senior Circuit Judge:
Three sets of taxpayers1 seek review of tax court decisions denying their petitions for redetermination of deficiencies with respect to losses claimed on investments in computer equipment leasing activities. The tax court concluded that a portion of the claimed losses under long-term installment partial recourse notes used to purchase equipment were in substance nonrecourse obligations and subject to a loss...
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