WATERS v. C.I.R.

No. 1512, Docket 92-4023.

978 F.2d 1310 (1992)

John J. WATERS and Jeanne M. Waters, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided October 21, 1992.


Attorney(s) appearing for the Case

Stephen D. Gardner (Ann-Elizabeth Purintun, Peter L. Ente, Kronish, Lieb, Weiner & Hellman, New York City, of counsel), for petitioners-appellants.

Bruce R. Ellisen, Attorney (James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, William J. Patton, Attorneys, Tax Div., Dept. of Justice, Washington, D.C.), for respondent-appellee.

Before: PRATT, MAHONEY and McLAUGHLIN, Circuit Judges.


MAHONEY, Circuit Judge:

John J. and Jeanne M. Waters appeal from a decision of the United States Tax Court, Stephen J. Swift, Judge, which ruled, inter alia, that John Waters ("Waters") was protected against loss, and therefore not "at risk" within the meaning of § 465 of the Internal Revenue Code of 1954,1 with respect to a nominally recourse note executed in connection with his investment in the purchase and lease...

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