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WHITMIRE v. C.I.R.

No. 98-70495.

178 F.3d 1050 (1999)

Robert L. WHITMIRE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 28, 1999.

Attorney(s) appearing for the Case

Stephen D. Gardner, Kronish, Lieb, Weiner & Hellman, New York, New York, for the plaintiff-appellant.

Joan I. Oppenheimer, United States Department of Justice, Washington, D.C., for the defendant-appellee.

Before: O'SCANNLAIN, WARDLAW, and FLETCHER, Circuit Judges.

WARDLAW, Circuit Judge:

We are asked to determine the extent of loss protection a taxpayer may build into a business transaction so as to eliminate any realistic possibility of actual loss from an unprofitable deal, yet remain "at risk" and entitled to a deduction for invested amounts under Internal Revenue Code 26 U.S.C. § 465. This issue arose in 1980, when taxpayer Robert L. Whitmire ("Whitmire") claimed an "at risk" deduction under section 465 for his investment...

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