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RICHARDSON v. C.I.R.

No. 81-4387.

693 F.2d 1189 (1982)

Cecil R. RICHARDSON and Doris C. Richardson, George Schneider, Jr. and Mary Ann Schneider, and Irwin J. Rice and Martha J. Rice, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

December 20, 1982.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, David English Carmack, Stephen Gray, Tax Division, Dept. of Justice, Kenneth W. Gideon, Chief Counsel, I.R.S., John H. Menzel, Director, Tax Lit. Div., Chief Counsel, Washington, D.C., for petitioners-appellants.

D. Irvin Couvillion, Baton Rouge, La., for respondent-appellee.

Before RUBIN, RANDALL and JOLLY, Circuit Judges.

RANDALL, Circuit Judge:

Two of the taxpayers in this case were admitted as partners in each of three limited partnerships on the last day of the partnership's taxable year. Each taxpayer appeals from the judgment of the Tax Court denying him a deduction, provided for in the related partnership agreement, for losses incurred by the partnership prior to the date on which he was admitted as a partner. The third taxpayer was a partner in all three partnerships throughout...

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