The case involves six people who were convicted of charges related to fraud in the tax treatment of stock sales and repurchase arrangements. The defendants argued that their arrangements didn't comply with section 1058 of the tax code, and that they had a good faith belief that they were following the law. The court found that the district court made mistakes in its instructions to the jury, and in its evaluation of evidence presented by the appellants. The case also involves allegations of securities fraud related to an underwritten convertible bond offering for a company called C.O.M.B. Co. The court found that some of the convictions were valid, while others were vacated and remanded to the district court for further proceedings.

United States v. Regan (1991)
United States Court of Appeals for the Second Circuit
937 F.2d 823

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