6611, LTD. v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 13088-05, 13250-05, 13251-05.

T.C. Memo. 2013-49

6611, LTD., RICARDO GARCIA, TAX MATTERS PARTNER, ET AL., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 14, 2013.


Attorney(s) appearing for the Case

William A. Roberts and Kyle R. Coleman , for petitioners.

Jeffrey Louis Bassin , Richard Hassebrock , Donna Leone , and Gary Shuler , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

HOLMES, Judge:

Three personal-injury lawyers from the Rio Grande Valley in Texas hit the jackpot in 2001 when each got paid over $1 million for their work in cases involving faulty Firestone tires. Each tried to reduce his tax bill with a complicated transaction that featured almost perfectly offsetting bets on foreign currency. Each of these lawyers was in the business of estimating risk and reward in evaluating every...

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