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DEEGAN v. C.I.R.

No. 949, Docket 85-4176.

787 F.2d 825 (1986)

John DEEGAN and Dorothy S. Deegan, Paul Schacknow, Stanley L. Manes and Jocelyn G. Manes, Jesse M. Farrow and Joan H. Farrow, Max H. Rhulen and Evelyn J. Rhulen, Walter A. Rhulen and Judith Rhulen, Jerome Reiss and Naomi Reiss, James P. Kelley and Louise Kelley, Harry E. Danielson and Mary Danielson, and Steven Roy Schacknow, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided April 8, 1986.

Attorney(s) appearing for the Case

Howard L. Mann, Schwartzman, Weinstock, Garelik & Mann, New York City (Herman Schwartzman and Donald A. Pitofsky, of counsel), for petitioners-appellants.

Teresa E. McLaughlin, Dept. of Justice, Tax Div., Washington, D.C. (Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup and Anne Belanger Durney, of counsel), for respondent-appellee.

Before KAUFMAN, MANSFIELD and MESKILL, Circuit Judges.

PER CURIAM:

Appellants are limited partners in Northern Hills Partnership ("Northern Hills"). Northern Hills was organized by general partner Ted Shapiro for the purpose of investing in two foreign films, "Ms. Don Juan"1 and "Don't Open the Window." "Ms. Don Juan," featuring Brigitte Bardot, follows the predictable exploits of a female Don Juan "who finds pleasure in destroying the lives of various men." "Don't Open the Window," a horror...

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