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HOLDERNESS v. C. I. R.

No. 77-1683.

615 F.2d 401 (1980)

Ralph G. HOLDERNESS and Shirley J. Holderness, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided March 3, 1980.

Attorney(s) appearing for the Case

Joseph Levin, Dice, Sweeny, Sullivan & Feikens, Detroit, Mich., for petitioners-appellants.

M. Carr Ferguson, Asst. Atty. Gen., Jonathan S. Cohen, Gilbert E. Andrews, John A. Dudeck, Tax Div., U. S. Dept. of Justice, Washington, D. C., Stuart E. Seigel, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before EDWARDS, Chief Judge, and CELEBREZZE and BROWN, Circuit Judges.

PER CURIAM.

Plaintiffs-appellants Holderness, who are husband and wife, appeal from a decision of the United States Tax Court affirming the Commissioner's disallowance of deductions for travel and entertainment expenses and losses incurred in the operation of a horse farm. They contend that they did provide adequate substantiation for the business character of the expense items and that the Commissioner should have allowed deduction of losses for the five horse ranch...

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