𝔖 Bobbio Scriptorium
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Smith and jacobson VS. IRS

✍ Scribed by Ronald J. Horowitz

Publisher
John Wiley and Sons
Year
1982
Tongue
English
Weight
135 KB
Volume
2
Category
Article
ISSN
0270-7314

No coin nor oath required. For personal study only.

✦ Synopsis

Smith and Jacobson vs. IRS Edited by Ronald J. Horowitz, Esq.

he longawaited "tax straddle case" has been decided and it is difficult to T determine who the real winner is. The decision in this case has been long awaited by many who utilized this tax-advantaged transaction until the Economic Recovery Tax Act of 1981 closed the "loophole."

The decision in the Smith and Jacobson cases was filed on March 5, 1982 and while Judge Nims held for the IRS, his reasoning would appear to enable many creative tax attorneys to distinguish the motives and intentions of their clients from those of the taxpayers in this case. From the facts, it would appear that the IRS picked a case it could not lose.

In 1973, the taxpayers entered into a transaction known as a butterfly straddle. This is a combination of two straddles and would therefore consist of four legs appearing as follows:

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