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HUGHES & LUCE, L.L.P. v. C.I.R.

No. 95-60036.

70 F.3d 16 (1995)

HUGHES & LUCE, L.L.P., Alan J. Bogdanow, Tax Matters Partner, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

November 15, 1995.

Attorney(s) appearing for the Case

Vester T. Hughes, Jr., J. Gregory Taylor, David Hernandez, Hughes & Luce, L.L.P., Dallas, TX, Jay Howell Hebert, Dallas, TX, for petitioners-appellants.

Gary R. Allen, U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Gilbert S. Rothenberg, Richard Bradshaw Farber, Thomas J. Clark, U.S. Dept. of Justice, Tax Div., Washington, DC, for C.I.R.

Before REAVLEY, JOLLY and WIENER, Circuit Judges.

WIENER, Circuit Judge.

This federal income tax case finds a law firm appealing from an adverse judgment rendered by the United States Tax Court. The underlying dispute arose when, during the course of an audit, the Internal Revenue Service (IRS) determined that "Service Costs" deducted by Hughes & Luce, L.L.P. should be treated as nondeductible loans to clients. The instant controversy concerns the collateral issue of the proper tax treatment of currently-received...

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