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HARRIS v. C.I.R.

No. 92-5097.

16 F.3d 75 (1994)

Joseph R. HARRIS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 10, 1994.

Attorney(s) appearing for the Case

H. Karl Zeswitz, Jr., Jenny Baker, Jean H. Baker, Baker and Hostetler, Washington, DC, for petitioner-appellant.

Abraham N.M. Shashy, Jr., Chief Counsel, IRS, Washington, DC, Shirley D. Peterson, Asst. Atty. Gen., U.S. Dept. of Justice, Tax Div., Washington, DC, Annette M. Wietecha, Charles Bricken, Gary R. Allen, Ann B. Durney, Chief Appellate Sec., Tax Div., Dept. of Justice, Washington, DC, for respondent-appellee.

Before POLITZ, Chief Judge, REYNALDO G. GARZA, and JOLLY, Circuit Judges.

E. GRADY JOLLY, Circuit Judge:

The taxpayer appeals from the Tax Court's denial of his deduction of his distributive share of payments made by his partnership to a corporation as a research and development expense under 26 U.S.C. § 174(a)(1). Because we find the partnership did not pay for research and development "in connection with" its own trade or business, we affirm the Tax Court.

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