This section contains the nature of the case and procedural background.

Omni (D) marketed an investment program involving commodity futures trades on the London Metals Exchange. D employed Rudolf Wolff & Co. (D1) as a broker to handle the trades. The IRS disallowed tax deductions claimed by participants in D's program and they, in turn, sued D. The IRS claimed that the trades in London were not bona fide arm's length transactions. D in turn impleaded D1 contending that its liability was caused by D1's improper trading activities. D1 moved to dismiss for lack of personal jurisdiction. The Supreme Court granted certiorari.

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