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HENDRICKS v. C.I.R.S.

No. 93-2453.

32 F.3d 94 (1994)

Daniel E. HENDRICKS; Barbara E. Hendricks, Petitioners-Appellants, v. COMMISSIONER of the INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided August 10, 1994.

Attorney(s) appearing for the Case

ARGUED: Michael Edwin Caryl, Bowles, Rice, McDavid, Graff & Love, Martinsburg, WV, for appellants. William J. Patton, Tax Div., U.S. Dept. of Justice, Washington, DC, for apllee. ON BRIEF: David A. DeJarnett, Bowles, Rice, McDavid, Graff & Love, Martinsburg, WV, for appellants. Loretta C. Argrett, Asst. Atty. Gen., Gary R. Allen, Teresa E. McLaughlin, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellee.

Before ERVIN, Chief Judge, MICHAEL, United States District Judge for the Western District of Virginia, sitting by designation, and ELLIS, United States District Judge for the Eastern District of Virginia, sitting by designation.

Affirmed by published opinion. Judge ELLIS wrote the opinion, in which Chief Judge ERVIN and Judge MICHAEL joined.

OPINION

ELLIS, District Judge:

Appellants, a West Virginia surgeon and his wife,1 appeal a United States Tax Court decision disallowing certain deductions and finding that defendants owed additional taxes. This result followed the Tax Court's determination that appellants' operation of a farm in Jefferson...

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