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YOSHA v. C.I.R.

No. 87-2342.

861 F.2d 494 (1988)

Louis Buddy YOSHA, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided November 8, 1988.

Attorney(s) appearing for the Case

Martin M. Ruken, Vedder Price Kaufman & Kammholz, Chicago, Ill., for petitioners-appellants.

Kenneth L. Greene, Atty. Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before POSNER, FLAUM and MANION, Circuit Judges.

POSNER, Circuit Judge.

The eternal tension between form and substance is the topic of this tax appeal. In Glass v. Commissioner, 87 T.C. 1087 (1986), following massive consolidated pretrial and trial proceedings, the Tax Court upheld the Internal Revenue Service's disallowance of deductions (aggregating some $100 million) claimed by more than 1,400 taxpayers for losses allegedly incurred trading option straddles and hedges on...

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