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FERGUSON v. C.I.R.

Nos. 1699, 1700, 1701, 1702, 1703, 1704, Dockets 93-4210, 93-4212, 93-4214, 93-4216, 93-4218, 93-4220.

29 F.3d 98 (1994)

Robert FERGUSON, John Allen, Joseph Arle, Paul Benchwick, Victor Blaha, Richard Doran, Lionel Gordon, Joseph Halpin, Ben Johnson, Thomas Katopody, Carlton Marshall, E. Barger Miller, Maurice Richards, John Rudy, II, Richard Sandler, Donna Sandler, Ira Sontupe, Harold Witham, Gail Witham, David Zuehlke, John McCurdy, a notice partner, Keith Gaskell, a notice partner, Petitioners-Appellants. Peat Oil and Gas Associates, James Karr, partner other than the Tax Matters partner, Syn-Fuel Associates, 1982, a partner other than the Tax Matters partner, Peat Oil and Gas Associates, a Limited Partnership, Joseph Yadgaroff and Robert Ferguson, a partner other than the Tax Matters partner, and Syn-Fuel Associates, A Limited Partnership, Keith Gaskell, a partner other than the Tax Matters partner, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided July 13, 1994.

Attorney(s) appearing for the Case

Dennis N. Brager, Los Angeles, CA (Jackson D. Hamilton, Roberts, Stevens & Cogburn, Asheville, NC, of counsel), for appellants.

Mary Frances Clark, Dept. of Justice, Washington, DC (Loretta C. Argrett, Asst. Atty. Gen., Gary R. Allen, David I. Pincus, Dept. of Justice, of counsel), for appellee.

Before: MESKILL, MINER and MAHONEY, Circuit Judges.

PER CURIAM:

In this tax appeal, the petitioners-appellants challenge the decision of the United States Tax Court, Cohen, J., to affirm the disallowance of certain deductions by the respondent Commissioner of Internal Revenue (Commissioner). We affirm.

BACKGROUND

The tax court's opinion fully describes the underlying facts of this case, see Peat Oil and Gas Associates v. Commissioner, 100 T.C. 271 (1993...

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