INDEPENDENT ELEC. SUPPLY, INC. v. C.I.R.

Nos. 85-7060, 85-7077.

781 F.2d 724 (1986)

INDEPENDENT ELECTRIC SUPPLY, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Frank PRESTIPINO and Leana Prestipino, Hildegard K. Marks, and Jean D. Littlefield, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided January 24, 1986.


Attorney(s) appearing for the Case

Clarence J. Ferrari, San Jose, Cal., for Independent Elec. Supply.

J. Richard Johnston, Johnston & Horton, Oakland, Cal., for petitioners-appellants.

Richard Driscoll, Ann Belanger Durney, Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before WRIGHT, KENNEDY, and BEEZER, Circuit Judges.


KENNEDY, Circuit Judge:

The taxpayers in these consolidated cases appeal the Tax Court's disallowance of deductions for depreciation, ordinary and necessary business expenses, and research and development expenses.1 We affirm.

The appellants each invested in limited partnerships, trusts, or both, set up by Fred Solomon and George Nicoladze for the ostensible purpose of acquiring and exploiting patents. The patents were acquired...

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