GOMBERG v. C.I.R.

No. 88-1160.

868 F.2d 865 (1989)

Edward N. GOMBERG and Helen E. Gomberg, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided February 28, 1989.


Attorney(s) appearing for the Case

Gary R. Allen, Chief, U.S. Dept. of Justice, Appellate Section Tax Div., David M. Moore (argued), Washington, D.C., for C.I. R.

Shelley Cashion, Chamberlain, Hrdlicka, White, Johnson & Williams, Houston, Tex., David D. Aughtry (argued), Chamberlain, Hrdlicka, White, Johnson & Williams, Atlanta, Ga., for Edward N. Gomberg.

Before ENGEL, Chief Judge, WELLFORD and BOGGS, Circuit Judges.


WELLFORD, Circuit Judge.

Petitioners-appellants, Edward and Helen Gomberg, appeal the United States Tax Court decision in Patin v. Commissioner, 88 T.C. 1086 (1987), upholding the Commissioner of the Internal Revenue Service's disallowance of a $120,000 deduction from the Gombergs' 1980 gross income in connection with a gold and silver mine investment. Gomberg also challenges the assessment of an interest penalty for tax motivated...

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