Attorney(s) appearing for the Case
George W. Connelly , [Argued], Chamberlain, Hrdlicka, White, Johnson & Williams, Houston, TX, for Appellant.
Gary R. Allen , Tamara W. Ashford , Richard Farber , Judith A. Hagley , [Argued], Gilbert S. Rothenberg , United States Department of Justice, Tax Division, Washington, DC, for Commissioner of Internal Revenue.
Before: RENDELL, FISHER, and JORDAN, Circuit Judges.
United States Court of Appeals, Third Circuit.
OPINION OF THE COURT
JORDAN, Circuit Judge.
Neal D. Crispin appeals the decision of the United States Tax Court that he was not entitled to an ordinary loss deduction for his participation in a Custom Adjustable Rate Debt Structure ("CARDS") transaction and that he is liable for an accuracy-related penalty under § 6662 of the Internal Revenue Code ("I.R.C.").1 The Tax Court disallowed the claimed loss on the grounds that...
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