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STEEN v. C. I. R.

No. 74-2185.

508 F.2d 268 (1975)

John T. STEEN and Nell D. Steen, Plaintiffs-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied March 25, 1975.

Attorney(s) appearing for the Case

John W. Davidson, Richard W. Wolf, Joe C. Elliott, San Antonio, Tex., for plaintiffs-appellants.

Scott P. Crampton, Asst. Atty. Gen., Tax Div., Dept. of Justice, Chris J. Ray, Atty., Meade Whitaker, Chief Counsel, Internal Revenue Service, Meyer Rothwacks, Chief, App. Sec., Tax. Div., Dept. of Justice, Ernest J. Brown, Gary R. Allen, Donald H. Olson, Attys., Tax. Div., Dept. of Justice, Gilbert E. Andrews, Acting Chief, App. Sec., Dennis M. Donohue, Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before DYER, MORGAN and GEE, Circuit Judges.

PER CURIAM:

Treating the main house, pool house and guest house on his River ranch as farm buildings, Steen claimed a deduction for depreciation in the years 1968 and 1969. The Commissioner disallowed the deduction, the Tax Court upheld the Commissioner, 61 T.C. 298, and Steen appealed. We affirm.

The houses were on the ranch at the time of its purchase by Steen. The main house was put to three uses: Steen and his foreman would...

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