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BEYER v. C.I.R.

No. 89-2843.

916 F.2d 153 (1990)

Arthur BEYER; Catherine A. Beyer, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided October 15, 1990.

Attorney(s) appearing for the Case

Charles W. Hall, Fulbright & Jaworski, Houston, Tex., argued (Steven E. Segal, John R. Allender, Mary Frances Lapidus, Fulbright & Jaworski, Houston, Tex., Moe K. Karash, Forest Hills, N.Y., Keith A. Jones, Washington, D.C., on the brief), for petitioners-appellants.

Teresa Thomas Milton, Tax Div., U.S. Dept. of Justice, Washington, D.C., argued (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, Gilbert S. Rothenberg, Tax Div., U.S. Dept. of Justice, Washington, D.C., on the brief), for respondent-appellee.

Before WIDENER, Circuit Judge, McMILLAN, Senior District Judge for the Western District of North Carolina, sitting by designation, and YOUNG, Senior District Judge for the District of Maryland, sitting by designation.

JOSEPH H. YOUNG, Senior District Judge:

This appeal presents an issue of first impression in this court concerning the carry-over provision of § 163(d)(2) of the Internal Revenue Code (IRC). The Tax Court held that the carry-over is subject to an implicit limitation equal to the taxpayer's total taxable income for the year in which the expense was incurred. After reviewing the language of the statute and the legislative history behind the carry-over provision...

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