Michael Malone v. Ahrens & Deangeli
Opinion
Opinion
MEMORANDUM
Michael and Barbara Malone appeal the dismissal of their claims against various defendants connected to Michael Malone’s (Michael’s) investment in an abusive tax shelter. Although the Malones named numerous parties as defendants in this action, the appellees here are limited to: (1) Bayerische Hypo-und Vereinsbank AG-New York Branch (HVB-NY), HVB U.S. Finance f/k/a HVB Structured Finance (HVB-Finance), and Bayerische-und Vere-insbank AG (HVB-AG) (collectively, HVB); (2) Enterprise Financial Services and the former president of one of its subsidiaries, Paul Vogel (collectively, Enterprise); (8) the Seattle law firm of Ah-rens & DeAngeli, PLLC and one of its partners, Edward Ahrens (collectively, A & D); and (4) Multi National Strategies, LLC, Coastal Trading LLC, Michael N. Schwartz, and David Schwartz (collectively, MNS). All of the Malones’ claims arise out of Michael’s investment in an abusive tax shelter called the Coastal Trading Common Trust Fund (CTF). The district court, through a series of motions either to dismiss or for summary judgment, ultimately dismissed all of the claims against the various appellees.