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GRIGG v. C.I.R.

No. 92-4131.

979 F.2d 383 (1992)

Richard A. GRIGG and Mary G. Grigg, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

December 21, 1992.

Attorney(s) appearing for the Case

J. Michael Weiss, Lubbock, Tex., for petitioners-appellants.

Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S., Jordan Glickstein, Gary R. Allen, Chief, Appellate Section, Ann B. Durney, James A. Bruton, Shirley D. Peterson, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before KING, JOHNSON, and DUHÉ, Circuit Judges.

JOHNSON, Circuit Judge:

This case calls on the Court to construe the hotel exception of section 280A of the U.S. Internal Revenue Code.1 The district court construed the exception such that the Griggs could not take advantage of it, holding that they were not entitled to claim certain deductions for their South Padre Island Condominium. The Griggs have appealed that decision. We affirm.

I. Facts and Procedural History

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