RESALE MOBILE HOMES, INC. v. C.I.R.

No. 90-9015.

965 F.2d 818 (1992)

RESALE MOBILE HOMES, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

May 22, 1992.


Attorney(s) appearing for the Case

Robert Shaiman, Lohf, Shaiman & Ross (John D. Moats and Mark H. Scheffel, John D. Moats & Associates, with him, on the briefs), Denver, Colo., for petitioner-appellant.

Steven W. Parks, Atty., Tax Div. (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and David English Carmack, Attys., Tax Div., with him, on the brief), Dept. of Justice, Washington, D.C., for respondent-appellee.

Before LOGAN and SEYMOUR, Circuit Judges, and WINDER, District Judge.


LOGAN, Circuit Judge.

Petitioner Resale Mobile Homes, Inc., appeals a decision of the Tax Court affirming the Commissioner of Internal Revenue's determination of deficiencies in petitioner's federal income tax returns for the years 1978-1981. The Tax Court, in its opinion reported as Resale Mobile Homes, Inc., 91 T.C. 1085 (1988), found that petitioner must report anticipated participation...

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