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KEAN v. C. I. R.

Nos. 24843-24848.

469 F.2d 1183 (1972)

Harold C. & Margaret I. KEAN, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Inga L. BARDAHL, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Ole BARDAHL, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Murdock D. & Mary Ellen MacPHERSON, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. William R. & Dorothy L. MacPHERSON, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. C. E. MILAM & Verda Milam, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied December 18, 1972.

Attorney(s) appearing for the Case

Gerald R. Hergert (argued), Joseph H. Trethewey, Seattle, Wash., for appellants.

Paul M. Ginsburg (argued), K. Martin Worthy, Chief Counsel, Johnnie M. Walters, Asst. Atty. Gen., Washington, D. C., for appellee.

Before HAMLEY and KILKENNY, Circuit Judges, and WM. MATTHEW BYRNE, Jr., District Judge.

WM. MATTHEW BYRNE, Jr., District Judge:

Appellants, petitioners in the Tax Court, were shareholders in Ocean Shores Bowl, Inc., hereinafter referred to as Bowl, a Washington corporation. They appeal from a judgment of the Tax Court, 51 T.C. 337, invalidating Bowl's election under Subchapter S, §§ 1371-1379 of the Internal Revenue Code of 1954, and disallowing petitioners' deductions on their personal tax returns of their pro...

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