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REDDAM v. C.I.R.

No. 12-72135.

755 F.3d 1051 (2014)

John Paul REDDAM, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed June 13, 2014.

Attorney(s) appearing for the Case

David W. Wiechert (argued) and Jessica C. Munk , Law Office of David W. Wiechert, San Clemente, California, for Petitioner-Appellant.

Kathryn Keneally , Assistant Attorney General, Tamara W. Ashford , Deputy Assistant Attorney General, Gilbert S. Rothenberg , Richard Farber , and Judith A. Hagley (argued), Attorneys, Tax Division, Department of Justice, Washington, D.C., for Respondent-Appellee.

Before: JEROME FARRIS and ANDREW D. HURWITZ, Circuit Judges, and PAUL L. FRIEDMAN, District Judge.

OPINION

HURWITZ, Circuit Judge:

John Paul Reddam claimed a deduction on his 1999 tax return of $50,164,421 for a capital loss purportedly generated by several Cayman Islands entities. The Commissioner of Internal Revenue disallowed the deduction, finding that the transaction lacked economic substance. After a bench trial, the Tax Court affirmed. Reddam v. Comm'r, No. 22557-08, 2012 WL 1215220 (T.C. Apr. 11, 2012). We have jurisdiction over Reddam...

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