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CHAMBERLAIN v. C.I.R.

No. 94-40806.

66 F.3d 729 (1995)

Joseph P. CHAMBERLAIN and D. Kathleen Chamberlain, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied October 24, 1995.

Attorney(s) appearing for the Case

Stephen L. Williamson, Brett A. North, Montgomery, Barnett, Brown, Read, Hammond and Mintz, New Orleans, LA, for appellants.

Laurie Snyder, U.S. Dept. of Justice, Tax Division, Bruce R. Ellisen, Reviewer, U.S. Dept. of Justice, Washington, DC, David L. Jordan, Acting Chief Counsel, I.R.S., Washington, DC, Loretta Argrett, Asst. Atty. Gen., Tax Division, Dept. of Justice, Washington, DC, Gary R. Allen, Chief, Steven W. Parks, Appellate Section, Tax Division, U.S. Dept. of Justice, Washington, DC, for appellee.

Before POLITZ, Chief Judge, JONES and PARKER, Circuit Judges.

POLITZ, Chief Judge:

Taxpayers, Joseph P. and D. Kathleen Chamberlain,1 appeal the Tax Court's decision upholding the penalties assessed by the Commissioner of Internal Revenue. We affirm in part and reverse in part.

Background

Joseph P. Chamberlain became a partner in Great Plains Partners in 1981. The partnership's principal objective was to enter into forward contracts with First Western Government Securities...

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