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WADDELL v. C.I.R.

No. 87-7045.

841 F.2d 264 (1988)

Warner R. WADDELL and Jeanette I. Waddell, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 26, 1988.

Attorney(s) appearing for the Case

Henry W. Walther and John D. Humbert, Deering, Walther & Sands, Santa Monica, Cal., Russell Iungerich, Los Angeles, Cal., for petitioners-appellants.

Bruce R. Ellisen, U.S. Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before TANG, WIGGINS and KOZINSKI, Circuit Judges.

PER CURIAM:

Warner and Jeanette Waddell appeal from the United States Tax Court's redetermination of an income tax deficiency. We consider whether the tax court properly characterized various aspects of the Waddells' investment in computerized electrocardiogram (ECG) terminals.

Facts

In 1980, the Waddells went into the business of leasing ECG terminals and providing related services to health care providers. To that end, they purchased from Comp...

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