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LESLIE v. C.I.R.

No. 96-70880.

146 F.3d 643 (1998)

Robert G. LESLIE and Marilyn B. Leslie, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 27, 1998.

Attorney(s) appearing for the Case

Kevin M. McGuire, Law Offices of Federico Castelan Sayre, Newport Beach, California, for petitioners/appellants.

Laurie Snyder, United States Department of Justice, Tax Division, Washington, DC, for respondent/appellee.

Before: FERGUSON, THOMPSON, and O'SCANNLAIN, Circuit Judges.

O'SCANNLAIN, Circuit Judge:

We examine the lingering federal income tax consequences of participation in gold-futures "straddle" transactions in the early 1980's, when the top tax-rate bracket was 70%.

I

On their 1980, 1981, and 1982 federal income tax returns, Robert and Marilyn Leslie claimed gains and losses resulting from gold-futures "straddle" transactions that Robert entered into with futures commission merchant F.G. Hunter & Associates...

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