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COLLINS v. C.I.R.

Nos. 87-7337, 87-7352.

857 F.2d 1383 (1988)

David G. COLLINS; Pamela Collins; Bernie Gates; Maureen Gates; Anne Hamsley; and David Dister, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 30, 1988.

Attorney(s) appearing for the Case

Robert T. Gilleran, Los Angeles, Cal., for petitioners-appellants.

William S. Rose, Jr., Asst. Atty. Gen., Tax Div., Washington, D.C., for respondent-appellee.

Before GOODWIN and HALL, Circuit Judges, and PANNER, District Judge.

PANNER, Chief District Judge:

Taxpayers David and Pamela Collins, Bernie and Maureen Gates, Anne Hamsley, and David Dister (taxpayers), appeal the Tax Court's disallowance of deductions for mining development expenses and imposition of penalties for negligence.1 We affirm.

BACKGROUND

For centuries, rivers have deposited tiny flakes of gold on the sandy beaches of Cape Yakataga, Alaska. Taxpayers claimed mining development...

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