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NICHOLSON v. COMMISSIONER OF I.R.S.

No. 94-7688.

60 F.3d 1020 (1995)

Charles E. NICHOLSON, Jr. and Margaret K. Nicholson, Appellants v. COMMISSIONER OF INTERNAL REVENUE SERVICE.

United States Court of Appeals, Third Circuit.

Decided July 24, 1995.

Attorney(s) appearing for the Case

Barry A. Furman and Mark S. Halpern (argued), Furman & Halpern, P.C., Bala Cynwyd, PA, for appellants.

Loretta C. Argrett, Asst. Atty. Gen., Gary R. Allen, Richard Farber, and Thomas J. Clark (argued), Tax Div., Dept. of Justice, Washington, DC, for appellee.

Before: BECKER, NYGAARD, and ALITO, Circuit Judges.

OPINION OF THE COURT

ALITO, Circuit Judge:

The genesis of this appeal is a decision by the Commissioner of the Internal Revenue Service ("the Commissioner") to disallow certain deductions claimed by Charles and Margaret Nicholson on their 1983, 1984, 1985, and 1986 tax returns regarding computer equipment that Charles Nicholson acquired in 1983. The Commissioner maintained that the Nicholsons were not entitled to take the deductions because Charles Nicholson...

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