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SENNETT v. C.I.R.

No. 83-7758.

752 F.2d 428 (1985)

William SENNETT and Sandra Sennett, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided January 22, 1985.

As Amended April 9, 1985.

Attorney(s) appearing for the Case

Harry Margolis, Los Gatos, Cal., for petitioners-appellants.

Raymond Hepper, Washington, D.C., for respondent-appellee.

Before WALLACE, HUG and SCHROEDER, Circuit Judges.

PER CURIAM.

Taxpayers William and Sandra Sennett claimed an ordinary loss deduction of $109,061 on their 1969 tax return. This loss represented William Sennett's share of the ordinary losses incurred in 1968 by Professional Properties Partnership ("PPP") when it repurchased his interest in the partnership. The Commissioner of Internal Revenue disallowed the deduction asserting inter alia that in 1969 Sennett had no basis in an interest in PPP since he had left...

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