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  5. 756 F.2d 1039 (1985)
 

WRIGHT v. C.I.R.

No. 84-1217.

756 F.2d 1039 (1985)

Larrimore WRIGHT and Mary M. Wright, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided March 13, 1985.

Attorney(s) appearing for the Case

C. Richard Rayburn, Jr., Barbara J. Dean, Charlotte, N.C. (C. Richard Rayburn, Jr., P.A., Charlotte, N.C., on brief), for appellants.

Gary R. Allen, Tax Div., Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Thomas M. Preston, Tax Div., Dept. of Justice, Washington, D.C., on brief), for appellee.

Before MURNAGHAN and SPROUSE, Circuit Judges, and MICHAEL, United States District Judge for the Western District of Virginia, sitting by designation.

MICHAEL, District Judge:

The case comes before this court on an appeal from a decision of the United States Tax Court which upheld the determination of the Commissioner of the Internal Revenue of a deficiency in the appellants'-taxpayers' income taxes for the year 1976.

A brief statement of the salient facts in the case indicates that the taxpayer Wright, having been employed in an accounting firm as a partner, was solicited to join one Hamilton in Texfi Industries...

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