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LANEY v. COMMISSIONER OF INTERNAL REVENUE

No. 80-1937.

674 F.2d 342 (1982)

John A. LANEY and Jeanine Laney, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit. Unit A

Rehearing Denied May 28, 1982.

Attorney(s) appearing for the Case

Jeffrey H. Hubbard & Associates, Inc., Jeffrey H. Hubbard, Houston, Tex., for petitioners-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Sec., John F. Murray, Richard Farber, Attys., Tax Div., U. S. Dept. of Justice, Kenneth W. Gideon, Chief Counsel, Internal Revenue Service, Thomas M. Preston, Jr., Atty., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before BROWN and GOLDBERG, Circuit Judges.

JOHN R. BROWN, Circuit Judge:

John and Jeanine Laney appeal from a decision of the United States Tax Court upholding the Internal Revenue Service's determination of deficiencies in their federal income tax for the tax years 1971, 1972 and 1973. The fundamental question on appeal is whether the Tax Court correctly interpreted one path of the maze of financial transactions in which the Laneys were involved as a limited partnership with recourse liabilities, so that...

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