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CATALANO v. C.I.R.

No. 99-70909.

240 F.3d 842 (2001)

Patrick E. Catalano, Petitioner, v. Commissioner of Internal Revenue, Respondent.

United States Court of Appeals, Ninth Circuit.

Filed February 15, 2001.

Attorney(s) appearing for the Case

Patrick E. Catalano, Pro Se, San Francisco, California, for the petitioner-appellant.

Patricia Bowman, Department of Justice, Washington, D.C., for the respondent-appellee.

Before: Mary M. Schroeder, Chief Judge, Cynthia Holcomb Hall and William A. Fletcher, Circuit Judges.

PER CURIAM:

Patrick Catalano, an attorney, leased three boats to a corporation organized under subchapter S of the Internal Revenue Code. See 26 U.S.C. §§ 1361-79. He was the sole shareholder and used the boats to entertain clients. The corporation deducted the lease payments on its federal corporate income tax returns, so that the deductions reduced the corporate income that was passed through to Catalano. As the recipient of the lease payments,...

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