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LERMAN v. C.I.R.

Nos. 90-1813 to 90-1815 and 90-1835 to 90-1837.

939 F.2d 44 (1991)

Charles S. LERMAN and Barbara Lerman, Cross-Appellants at No. 90-1835 Appellees at No. 90-1813, v. COMMISSIONER OF INTERNAL REVENUE, Appellant at No. 90-1813 Cross-Appellee at No. 90-1835. Joseph L. FRAITES and Evelyn Fraites, Cross-Appellants at No. 90-1836 Appellees at No. 90-1814, v. COMMISSIONER OF INTERNAL REVENUE, Appellant at No. 90-1814 Cross-Appellee at No. 90-1836. Dwight B. MASSEY and Joann V. Massey, Cross-Appellants at No. 90-1837 Appellees at No. 90-1815, v. COMMISSIONER OF INTERNAL REVENUE, Appellant at No. 90-1815 Cross-Appellee at No. 90-1837.

United States Court of Appeals, Third Circuit.

Decided July 17, 1991.

Attorney(s) appearing for the Case

Elias Rosenzweig (argued), Stanley Klein, Michael Weitzner, Brauner, Baron, Rosenzweig, Kligler, Sparber, Bauman & Klein, New York City.

Shirley D. Peterson, Asst. Atty. Gen., Kenneth L. Greene (argued), Gary R. Allen, Kimberly S. Stanley, U.S. Dept. of Justice, Tax Div., Washington, D.C.

Before SLOVITER, Chief Judge, and GREENBERG and HIGGINBOTHAM, Circuit Judges.

OPINION OF THE COURT

GREENBERG, Circuit Judge.

Introduction

This case involves the continuing saga of a crackdown by the Commissioner of Internal Revenue on a tax shelter device we will call the "option-straddle transaction" and the divers attempts of various taxpayers to avoid the consequences of this crackdown.

The particular straddle transactions involved silver options on the London Metals Exchange. Appellant-taxpayers, Charles...

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