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ESTATE OF WALLACE v. C.I.R.

No. 91-7318.

965 F.2d 1038 (1992)

ESTATE OF Gerald L. WALLACE, Deceased, Celia A. Wallace, Executrix, and Celia A. Wallace, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

July 13, 1992.

Attorney(s) appearing for the Case

Roland J. Mestayer, Jr., Megehee, Mestayer, Kinard & Smith, P.A., Pasacagoula, Miss., Norman A. Lofgren, Clark S. Willingham, Mankoff, Hill, Held & Goldburg, P.C., Dallas, Tex., for petitioners-appellants.

Robert D. Forrester, Gibson, Ochsner & Adkins, L.L.P., Amarillo, Tex., for amicus.

Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S., Gary R. Allen, Chief, Joan J. Oppenheimer, Brian C. Griffin, Appellate Section, Tax Div., Washington, D.C., for respondent-appellee.

Before KRAVITCH and DUBINA, Circuit Judges, and RONEY, Senior Circuit Judge.

KRAVITCH, Circuit Judge:

Plaintiffs-Appellants Gerald L. Wallace ("Wallace"), deceased, and Celia A. Wallace, his wife and executrix, appeal from a tax court decision upholding the IRS's finding of tax deficiencies against the Wallaces for the years 1980 and 1983. The tax court ruled that the Wallaces were not entitled to deduct the entire cost of feed for their cattle-feeding business in the year in which the feed was purchased, and could only deduct the cost in...

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