No. 89-1586.

896 F.2d 10 (1990)

Robert M. BROWN, Petitioner, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided February 15, 1990.

Rehearing and Rehearing Denied April 4, 1990.

Attorney(s) appearing for the Case

Charles L. Abrahams, for petitioner, appellant.

Barbara I. Hodges, Tax Div., Dept. of Justice, with whom Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, and David English Carmack, Tax Div., Dept. of Justice, Washington, D.C., were on brief for respondent, appellee.

Before BREYER, ALDRICH and TORRUELLA, Circuit Judges.

Rehearing and Rehearing En Banc Denied April 4, 1990.


Taxpayer/petitioner Robert M. Brown is one of approximately 230 professional hockey players who, in 1975, received deficiency notices from the IRS for deductions for off-season expenses claimed in their 1972 income tax returns. In an effort to resolve these cases expeditiously, the Tax Court directed counsel and the Commissioner to designate two representative cases for litigation.

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