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  5. 877 F.2d 838 (1989)
 

POLLEI v. C.I.R.

Nos. 87-1159, 87-1160.

877 F.2d 838 (1989)

Jon R. and Carol J. POLLEI, and Harry W. and Renee L. Patrick, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

June 13, 1989.

Attorney(s) appearing for the Case

Steven D. Woodland, of Van Cott, Bagley, Cornwall & McCarthy, Salt Lake City, Utah, for petitioners-appellants.

Ann Belanger Durney, Tax Div., Dept. of Justice, Washington, D.C. (Roger M. Olsen, Asst. Atty. Gen., Michael L. Paup and B. Paul Klein with her on the brief), for respondent-appellee.

Before HOLLOWAY, SEYMOUR, and BALDOCK, Circuit Judges.

SEYMOUR, Circuit Judge.

Petitioners John R. Pollei and Harry W. Patrick1 appeal from the United States Tax Court's decision upholding deficiencies assessed against their federal income tax returns for 1981. At issue is whether petitioners may deduct as "ordinary and necessary" business expenses under section 162(a) of the Internal Revenue Code, 26 U.S.C. § 162(a) (1982), maintenance and operating costs arising from their use of personally...

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