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DUFRESNE v. C.I.R.

Nos. 92-70346, 92-70355, 92-70352, 92-70347, 92-70349 and 92-70662.

26 F.3d 105 (1994)

Robert L. DUFRESNE; Carolyn S. Dufresne, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. Jerry DIXON; Patricia Dixon, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. Richard HONGSERMEIER; Fiorella Hongsermeier, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. Hoyt W. YOUNG; Barbara D. Young, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. Terry D. OWENS; Gloria Owens, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. Ralph RINA, Petitioner-Appellant, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 14, 1994.

Attorney(s) appearing for the Case

Joe Alfred Izen, Jr., Bellaire, TX, for petitioners-appellants Robert L. DuFresne, et al.

Steven Parks, U.S. Dept. of Justice, Washington, DC, for respondent-appellee C.I.R.

Before GOODWIN, FERGUSON, and TROTT, Circuit Judges.

PER CURIAM:

These cases concern certain investment programs presented and managed by Henry Kersting. Kersting presided in Hawaii over numerous holding corporations, acceptance corporations, automobile leasing corporations, and lending institutions. He created and administered assorted investment programs which he sold primarily to commercial airline pilots. In each plan, a client obtained a primary loan from one Kersting corporation in order to purchase stock or an...

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