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EVANS v. C.I.R.

No. 89-2008.

908 F.2d 369 (1990)

John S. EVANS and Sue A. Evans, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided July 13, 1990.

Attorney(s) appearing for the Case

Walter J. Rockler, Washington, D.C., for appellants.

Teresa McLaughlin, Washington, D.C., for appellee.

Before LAY, Chief Judge, BEAM, Circuit Judge and HANSON, Senior District Judge.

BEAM, Circuit Judge.

John S. Evans and Sue A. Evans1 appeal the tax court's determination that John Evans' partnership, Heartbeat Associates, was not engaged in activities for the purpose of making a profit, a violation of 26 U.S.C. § 183 (1982 & Supp. IV 1986).2 The taxpayers also appeal the tax court's imposition of a penalty interest rate for a "tax motivated transaction" pursuant to 26 U.S.C. ...

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