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LEE v. C.I.R.

Nos. 87-2161, 88-1502.

897 F.2d 915 (1989)

Edward E. LEE, Jr. and Betty J. Lee, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Gerard J. SCHMIDT and Mary A. Schmidt, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided August 29, 1989.

Attorney(s) appearing for the Case

Martin M. Rukin, Chicago, Ill., for appellants.

Gary R. Allen, Washington, D.C., for appellee.

Before LAY, Chief Judge, JOHN R. GIBSON, Circuit Judge, and STUART, Senior District Judge.

LAY, Chief Judge.

These appeals arise from a decision of the tax court in consolidated proceedings sub nom. Glass v. Commissioner, 87 T.C. 1087 (1986). Jurisdiction in this court is based on 26 U.S.C. § 7482(a). In Glass, the tax court held that petitioners Edward and Betty Lee and Gerard and Mary Schmidt (taxpayers) wrongfully deducted ordinary losses under I.R.C. § 165(c)(2). The tax court further held that...

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