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MASSENGILL v. C.I.R.

No. 88-2738.

876 F.2d 616 (1989)

Preston W. and Joyce MASSENGILL, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided May 25, 1989.

Attorney(s) appearing for the Case

Preston W. Massengill, pro se.

William S. Rose, Jr., and David I. Pincus, Washington, D.C., for appellee.

Before ARNOLD, BOWMAN, and MAGILL, Circuit Judges.

ARNOLD, Circuit Judge.

At issue in this appeal from the United States Tax Court1 are appellant Preston Massengill's claimed depreciation deductions and investment tax credits based on his involvement in a cattle-breeding operation. The Tax Court held that Massengill's asserted purchases of cattle and his participation in breeding contracts had no economic substance, and should not be recognized for federal income tax purposes. Massengill...

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