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FOX v. C.I.R.

No. 88-1278.

874 F.2d 560 (1989)

Abe L. FOX and Shirley J. Fox; Estate of Phillip W. Pillsbury, Deceased, George S. Pillsbury and Charles S. Bellows, co-personal representatives and Corinne Pillsbury; John K. Whitney and Helen W. Whitney; Donald A. Jacobson and Sharon L. Jacobson; Estate of Starke R. Hathaway, Deceased, F & M Marquette National Bank, Representative and Virginia Hathaway; Northstar Computer Forms, Incorporated; and Raymond Dykema and Jeanne Dykema; and Thomas H. Wyman and Elizabeth M. Wyman, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided May 11, 1989.

Attorney(s) appearing for the Case

James A. Beitz, Minneapolis, Minn., for appellants.

Kimberly S. Stanley, Washington, D.C., for appellee.

Before HEANEY and BEAM, Circuit Judges, and LARSON, District Judge.

BEAM, Circuit Judge.

Fox and other taxpayers, partners in the Cedar Riverside Land Company, challenge the Tax Court's1 decision in favor of the Internal Revenue Service. The Tax Court upheld the Commissioner's disallowance of deductions taken by the taxpayers for interest accrued in 1978. We affirm.

I. BACKGROUND

A. Facts

Each taxpayer is a limited partner of Cedar Riverside Properties (CRP), a Minnesota limited...

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