SIMON v. C.I.R.

Nos. 86-5911 to 86-5914.

830 F.2d 499 (1987)

Herman SIMON and Ursula Simon v. COMMISSIONER OF INTERNAL REVENUE. Appeal of Herman SIMON and Ursula Simon. CONSOLIDATED LUMBER CORPORATION v. COMMISSIONER OF INTERNAL REVENUE. Appeal of CONSOLIDATED LUMBER CORP. Jack PEARLSTEIN and Thelma Pearlstein, Appellants, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided October 7, 1987.


Attorney(s) appearing for the Case

Guy R. Fairstein, (argued), Summit Rovins & Feldesman, New York City, for appellants.

Robert M. Olsen, Asst. Atty. Gen., Michael L. Raup, Anne Belanger Durney, Laura A. Snyder (argued), Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellee.

Before GIBBONS, Chief Judge, WEIS, Circuit Judge, KELLY, District Judge.


OPINION OF THE COURT

GIBBONS, Chief Judge.

These four consolidated appeals are from a final order of the United State Tax Court determining that there was a deficiency in the taxpayers' federal income tax for the taxable year 1976.1 At issue are claimed deductions for expenses paid or incurred in that year in carrying out a trade or business, or for the production or collection of income. 26 U.S.C. §§ 162(a)(3), 212...

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