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  5. 899 F.2d 905 (1990)
 

JAMES v. C.I.R.

Nos. 87-1913, 87-1916, 87-1918, 87-1919, 87-1959, 87-1960 and 87-1961.

899 F.2d 905 (1990)

Jack S. JAMES and Carol N. James; Glen E. Michael and Sybil H. Michael; A.F. Boudreau, Jr., and Katherine F. Boudreau; David G. Ownby and Kathleen Ownby; Jeffry H. Cope and Mary E. Cope; and Robert S. Cope and Phyllis H. Cope, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

March 26, 1990.

Attorney(s) appearing for the Case

Tom G. Parrott (Charles N. Woodward of Lisle & Woodward, with him on the briefs), Oklahoma City, Okl., for petitioners-appellants.

Thomas R. Lamons, Atty., Tax Div. (William S. Rose, Jr., Acting Asst. Atty. Gen., Michael L. Paup and Ann Belanger Durney, Attys., Tax Div., with him on the brief), Dept. of Justice, Washington, D.C., for respondent-appellee.

Before LOGAN, MOORE and TACHA, Circuit Judges.

LOGAN, Circuit Judge.

Petitioners Jack James, Glen and Sybil Michael, A.F. Boudreau, Jr., David Ownby, Jeffrey Cope, and Robert Cope were investors,1 either individually or through controlled entities, in joint ventures that purchased expensive computer systems already leased to large industrial corporations. These investors took deductions on their personal income tax returns for depreciation...

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