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TUCKER v. COMMISSIONER OF INTERNAL REVENUE

No. 17-60833.

KEITH A. TUCKER; LAURA B. TUCKER, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Filed April 3, 2019.

Attorney(s) appearing for the Case

Richard Bradshaw Farber, for Respondent-Appellee.

Gilbert Steven Rothenberg, for Respondent-Appellee.

Ellen Page DelSole, for Respondent-Appellee.

Phillip Joseph Taylor, for Petitioner-Appellant.

Norah Bringer, for Respondent-Appellee.

George Millington Clarke, III, for Petitioner-Appellant.

William M. Paul, for Respondent-Appellee.

David A. Hubbert, Tax Court, for Respondent-Appellee.

Mireille Rebecca Oldak, for Petitioner-Appellant.

Before: HIGGINBOTHAM, GRAVES, and WILLETT, Circuit Judges.

Taxpayers Keith Tucker and Laura Tucker, husband and wife, claimed a $39,188,666 loss deduction for the 2000 tax year resulting from Mr. Tucker's execution of a "customized solution" to mitigate the Taxpayers' income tax. The customized solution (the "FX Transaction") involved highly-complex, interrelated foreign...

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