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BETSON v. C.I.R. SERVICE

No. 85-7053.

802 F.2d 365 (1986)

J.R. BETSON, Jr. and Joan Sue Betson, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided October 17, 1986.

Attorney(s) appearing for the Case

Ronald K. Van Wert, Newport Beach, Cal., for petitioner-appellant.

Martha B. Brissette, William Whitledge, Dept. of Justice, Washington, D.C., for respondent-appellee.

Before KENNEDY, SKOPIL, and ALARCON, Circuit Judges.

KENNEDY, Circuit Judge:

Taxpayers J.R. Betson, Jr. and Joan Sue Betson (collectively "Betson") appeal the Tax Court's disallowance of deductions for 1970-1972 claimed under I.R.C. §§ 162, 165, and 212 in connection with the operation of certain retail liquor stores in New Mexico. The Tax Court found that the stores were in fact operated by Bethinol, Inc., a New Mexico corporation wholly owned by the taxpayers and formed "[t]o engage in the retail and wholesale...

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