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MARTUCCIO v. C.I.R.

No. 93-2001.

30 F.3d 743 (1994)

James V. MARTUCCIO; Louise A. Martuccio, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided July 28, 1994.

Attorney(s) appearing for the Case

J. Timothy Bender, Joseph P. Alexander, David G. Lambert (argued and briefed), Kadish & Bender, Cleveland, OH, for petitioners - appellants.

Bruce R. Ellisen, William J. Patton (argued), Gary R. Allen, Acting Chief (briefed), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, DC, for respondent - appellee.

Before: MILBURN and NELSON, Circuit Judges; and COOK, Chief District Judge.

MILBURN, Circuit Judge.

The issue in this appeal is whether petitioner James V. Martuccio1 was "at risk" under 26 U.S.C. § 465 for the recourse portion of an installment note he executed as consideration for the purchase of certain computer equipment. The Tax Court held that he was not. For the reasons that follow, we reverse and remand.

I.

This case involves a sale-leaseback transaction involving three major parties...

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