F. George Laverne Gary M. Gustin Deanne Gustin v. Commissioner Internal Revenue Service

956 F.2d 274 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. F. George LAVERNE; Gary M. Gustin; Deanne Gustin, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 90-70648. United States Court of Appeals, Ninth Circuit. Submitted Jan. 15, 1992. * Decided March 2, 1992. 1 Before GOODWIN, FLETCHER and BRUNETTI, Circuit Judges 2 MEMORANDUM ** OVERVIEW 3 This is an appeal from a Tax Court opinion deciding three consolidated test cases involving the deductibility of certain investments in limited partnerships known as Barbados No. 1 and Barbados No. 4. Two of the taxpayer petitioners appeal the Tax Court's decision; the third is not involved in this appeal because he resides outside the geographical boundaries and appellate jurisdiction of the Ninth Circuit. 1 The Tax Court found that the transactions at issue were "sham" transactions because they did not have economic substance beyond the creation of tax benefits. The Tax Court also…