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YOUNG v. C.I.R.

No. 89-70384.

923 F.2d 719 (1991)

William YOUNG; Ruby Young, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided January 16, 1991.

Attorney(s) appearing for the Case

Edward B. Simpson, Simpson & Gigounas, San Francisco, Cal., for petitioners-appellants.

Shirley D. Peterson, Asst. Atty. Gen., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before HUG, BEEZER and BRUNETTI, Circuit Judges.

HUG, Circuit Judge:

Appellants William and Ruby Young ("taxpayers") appeal the Tax Court order disallowing the allocation of 75% of the tax losses of Riverfront Associates, Ltd. ("Riverfront"), to one partner, Spokane Hotel Associates, Ltd. ("Spokane") on grounds that the allocation lacked economic substance. On appeal, taxpayers contend it was clear error for the Tax Court to find that the allocation lacked economic substance. We affirm.

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