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ECHOLS v. C.I.R.

No. 90-4231.

935 F.2d 703 (1991)

John C. ECHOLS and Deanna O. Echols, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

July 15, 1991.

Attorney(s) appearing for the Case

Bruce Locke, Shelley Cashion, Chamberlain, Hrdlicka, White, Johnson & Williams, Houston, Tex., for petitioners-appellants.

Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S., Doris D. Coles, Gary R. Allen, Chief, Charles Bricken, Shirley D. Peterson, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before GARWOOD and WIENER, Circuit Judges, and VELA, District Judge.

WIENER, Circuit Judge.

Petitioners, John C. Echols (Echols) and his wife, Deanna O. Echols (collectively, Taxpayers), appeal from that portion of the decision of the United States Tax Court which held that Taxpayers were not entitled to claim a deduction in 1976 under 26 U.S.C. Section 165(a) (§ 165(a) of the Internal Revenue Code of 1954 as amended (I.R.C.) and in effect for the years at issue in this case) on the basis of abandonment. The tax court found that...

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