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HAYDEN v. C.I.R.

No. 88-1964.

889 F.2d 1548 (1989)

Donald HAYDEN, Agnes Hayden, William P. Young, Mary E. Young, Lidio Medina, Patricia Medina, Donald L. Baltz, Judith H. Baltz, Carl Nagy, Dennis A. Lynch, Mary A. Lynch, Peter Nunez, Virginia Nunez, Robert J. Flynn, Julene F. Flynn, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided November 22, 1989.

Attorney(s) appearing for the Case

Howard K. Schwartz (argued), West Bloomfield, Mich., for petitioners-appellants.

William F. Nelson, I.R.S., Gary R. Allen, Acting Chief, William S. Rose, Jane S. Kimball, Ann Belanger Durney (argued), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for respondent-appellee.

Before: KENNEDY and NELSON, Circuit Judges, and WISEMAN, Chief District Judge.

KENNEDY, Circuit Judge.

Taxpayers appeal the decision of the United States Tax Court determining deficiencies in their federal income taxes from the disallowance of partnership loss deductions taken with respect to their investment in a tax shelter known as the Food Rethermalization Limited Partnership (Food Rethermalization).1 We hold that the Tax Court was not clearly erroneous in its findings and did not err in concluding that the taxpayers...

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