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McCOY v. UNITED STATES

Nos. 85-1997(L), 86-3014.

802 F.2d 762 (1986)

T. Ree McCOY, Nancy McCoy, Appellants, v. UNITED STATES of America, Appellee. (Two Cases)

United States Court of Appeals, Fourth Circuit.

Decided October 7, 1986.

Attorney(s) appearing for the Case

Richard E. Halperin (Shea & Gould, Harold P. Threlkeld on brief), for appellants.

William A. Whitledge, Tax Div., U.S. Dept. of Justice (Roger M. Olsen, Acting Asst. Atty. Gen., David English Carmack, Michael L. Paup, Vinton DeVane Lide, U.S. Atty. on brief), for appellee.

Before WINTER, Chief Judge, ERVIN, Circuit Judge, and HAYNSWORTH, Senior Circuit Judge.

HARRISON L. WINTER, Chief Judge:

Plaintiffs T. Ree McCoy and Nancy McCoy1 appeal from the district court's entry of summary judgment, denying them a refund of income taxes paid for the years 1978 and 1979. The McCoys had claimed that they were entitled to deductions for advance royalties paid in those years pursuant to mineral subleases entered into in 1978, but the district court ruled that, pursuant to the current version of Treasury...

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