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APACHE BEND APARTMENTS v. U.S. THROUGH I.R.S.

No. 91-1083.

964 F.2d 1556 (1992)

APACHE BEND APARTMENTS, LTD., et al., Plaintiffs-Appellants, v. UNITED STATES of America, Acting Through the INTERNAL REVENUE SERVICE, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

June 25, 1992.

Attorney(s) appearing for the Case

Patrick A. Barbolla, Ft. Worth, Tex., for plaintiffs-appellants.

Teresa E. McLaughlin, Gary R. Allen, Chief, Gilbert S. Rothenberg, Asst. Chief, Appellate Sec., Tax Div., Dept. of Justice, Washington, D.C., for defendants-appellees.

Before GOLDBERG, JOLLY, and WIENER, Circuit Judges.

GOLDBERG, Circuit Judge:

In an effort to dampen the impact of the radical changes brought about by the Tax Reform Act of 1986, Congress provided certain taxpayers exemptions from the new tax laws. In many instances, Congress designed these exemptions, known as "transition rules," to favor only one or a very few taxpayers. The method by which Congress selected those taxpayers that would enjoy the benefit of the transition rules is the subject of this lawsuit.

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