GATTO v. C.I.R.

No. 91-70613.

1 F.3d 826 (1993)

Michael GATTO; Philip Gatto, Stephanie Gatto, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 26, 1993.


Attorney(s) appearing for the Case

Steven J. Cannata, Cannata & Papale, San Francisco, CA, for petitioners-appellants.

Teresa T. Milton, U.S. Dept. of Justice, Tax Div., Washington, DC, for respondent-appellee.

Before: HUG, FLETCHER, and BRUNETTI, Circuit Judges.


HUG, Circuit Judge:

Michael, Philip, and Stephanie Gatto appeal the Tax Court's denial of two income tax deductions which they had claimed for the 1980, 1981 and 1982 tax years: (I) a deduction under 26 U.S.C. § 163 for interest on loans which had been granted to the Gattos by trusts of their own creation, and (II) a deduction under 26 U.S.C. § 174 for research expenditures incurred by certain research and development partnerships in which they were limited...

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