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HUDSPETH v. UNITED STATES

No. 75-2492 Summary Calendar.

519 F.2d 1055 (1975)

George A. HUDSPETH and wife, Vona Lee Hudspeth, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

September 19, 1975.

Attorney(s) appearing for the Case

George A. Hudspeth, pro se.

Frank D. McCown, U. S. Atty., Ft. Worth, Tex., Scott P. Crampton, Asst. Atty. Gen., U. S. Dept. of Justice, Tax Div., Gilbert E. Andrews, Act. Chief, App. Sec., U. S. Dept. of Justice, William W. Guild, Jonathan S. Cohen, Daniel F. Ross, Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before WISDOM, BELL and CLARK, Circuit Judges.

PER CURIAM:

Taxpayers deducted a decrease in their cotton allotment as a business loss in 1971. The deduction was disallowed, and taxpayers sued in district court for a refund. Summary judgment was granted in favor of the United States on the basis that there was no closed transaction giving rise to a deductible business loss. We affirm.

In the years 1968 through 1970, the taxpayers bought cotton acreage allotments...

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