No. 90-70266.

933 F.2d 757 (1991)

Diana T. VORSHECK; John P. Vorsheck, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 16, 1991.

Attorney(s) appearing for the Case

Diana Vorsheck and John P. Vorsheck, pro se.

Shirley D. Peterson, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before BROWNING, GOODWIN and POOLE, Circuit Judges.


Diana Todaro Vorsheck and John P. Vorsheck appeal pro se the tax court's decision upholding the Commissioner of Internal Revenue's ("Commissioner") determination of a tax deficiency of $10,910 for the 1982 tax year. The tax court upheld the Commissioner's disallowance of a deduction for losses incurred through their investment in Western Reserve Oil & Gas Co., Ltd. ("WROG"), a limited partnership, because WROG did not have a profit motive. In addition...

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