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CRC CORP. v. C.I.R.

Nos. 82-3009, 82-3010.

693 F.2d 281 (1982)

CRC CORPORATION, Appellant, v. COMMISSIONER OF INTERNAL REVENUE. CRC CORPORATION v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Third Circuit.

Decided November 16, 1982.

Attorney(s) appearing for the Case

Thomas B. Rutter (argued), Thomas B. Rutter, Ltd., Philadelphia, Pa., for CRC Corp.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Ann Belanger Durney, George L. Hastings, Jr. (argued), Attys., Tax Div., Dept. of Justice, Washington, D.C., for C.I.R.

Before GIBBONS, WEIS and SLOVITER, Circuit Judges.

OPINION OF THE COURT

GIBBONS, Circuit Judge.

The Commissioner of Internal Revenue appeals from a decision of the United States Tax Court with respect to the federal income tax liability of CRC Corporation for the calendar year 1972. The taxpayer cross-appeals from that decision to the extent that it disallowed deduction of certain abandonment losses. At issue in the Commissioner's appeal is the tax treatment of deductions by a limited partner in an oil and...

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