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IDAHO FIRST NAT. BANK v. C.I.R.

No. 91-70697.

997 F.2d 1285 (1993)

IDAHO FIRST NATIONAL BANK; Moore Financial Group, Inc., Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided June 24, 1993.

Order Clarifying Decision August 4, 1993.

Attorney(s) appearing for the Case

Gary R. Allen and Joan I. Oppenheimer, Dept. of Justice Tax Div., Washington, DC, for respondent-appellant.

Robert J. Jones, Steven P. Lockman, Robert P. Hanson, and L. Hope O'Keeffe, Arnold & Porter, Washington, DC, for petitioners-appellees.

Before: HUG, GOODWIN, and FLETCHER, Circuit Judges.

PER CURIAM:

Respondent-appellant Commissioner of Internal Revenue ("Commissioner") appeals a tax court decision construing 26 C.F.R. § 1.1502-15(a)(2) (1992) in favor of petitioner-appellees Moore Financial Group, Inc. and Idaho First National Bank (collectively, "petitioners"). Petitioners filed consolidated federal tax returns in which they offset losses of an acquired corporation against other consolidation group members' taxable income. We reverse.

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