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BROWN v. C.I.R.

No. 82-1372.

706 F.2d 755 (1983)

Frederick G. BROWN, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

May 4, 1983.

Attorney(s) appearing for the Case

Thomas P. Casey (argued), Troy, Mich., for Petitioners-appellants.

Kenneth W. Gideon, Chief Counsel, I.R.S., John Griffin (argued), Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before MERRITT and WELLFORD, Circuit Judges, and TIMBERS, Senior Circuit Judge.

ORDER

Petitioners appeal the Tax Court's decision holding them liable for tax deficiencies for the years 1970, 1971, and 1972. As shareholders in the Flint Motor Inn Company, a Subchapter S corporation, petitioners claimed deductions under § 1374 of the Internal Revenue Code to reflect the corporation's operating losses during the three years in question. These deductions included pro rata shares of a $400,000...

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