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ORVIS v. C.I.R.

No. 84-7873.

788 F.2d 1406 (1986)

Thomas V. ORVIS and Bobye G. Orvis, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 1, 1986.

Attorney(s) appearing for the Case

Thomas V. Orvis, Bobye G. Orvis, pro se.

Glenn L. Archer, Jr., Asst. Atty. Gen., I.R.S., Teresa McCaughlin, Dept. of Justice, Washington, D.C., for respondent-appellee.

Before REINHARDT, BEEZER, and HALL, Circuit Judges.

CYNTHIA HOLCOMB HALL, Circuit Judge:

This case raises two questions under the Internal Revenue Code of 1954 (the "Code") as in effect in 1978:1 (1) whether a taxpayer's contribution to an individual retirement account is deductible when the taxpayer is a participant in another qualified retirement plan for a portion of the tax year, and (2) whether an item is deductible as a necessary expense of a taxpayer's trade or business when the...

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