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RESER v. C.I.R.

No. 96-60393.

112 F.3d 1258 (1997)

Rebecca Jo RESER, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

May 12, 1997.

Attorney(s) appearing for the Case

O. Jan Tyler, William M. Boyd, Boyd & Veigel, McKinney, TX, for Petitioner-Appellant.

Teresa T. Milton, Richard Bradshaw Farber, Gary William Allen, Department of Justice, Tax Division, Appellate Section, Washington, DC, Stuart L. Brown, Chief Counsel, Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before JOLLY, JONES and WIENER, Circuit Judges.

WIENER, Circuit Judge:

Petitioner-Appellant Rebecca Jo Reser (Reser) appeals the Tax Court's decision disallowing certain deductions that she and her former husband, Don C. Reser (Don), claimed on their 1987 and 1988 joint income tax returns. The deductions represented losses incurred by Don's subchapter S corporation for those years. Reser asserts, in the alternative, that she is not liable for any deficiency determined by the Tax Court on the 1987 joint return,...

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