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L & C SPRINGS ASSOCIATES v. C.I.R.

No. 98-2970.

188 F.3d 866 (1999)

L & C SPRINGS ASSOCIATES, Century Capital Corporation, and Tax Matters Partner, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided: August 18, 1999.

Attorney(s) appearing for the Case

Randall G. Dick (argued), Jeffer, Mangels, Butler & Marmaro, San Francisco, CA, for Petitioners-Appellants.

Curtis C. Pett (argued), Department of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.

Before RIPPLE, DIANE P. WOOD and EVANS, Circuit Judges.

RIPPLE, Circuit Judge.

The Internal Revenue Service determined adjustments to L & C Springs Associates' income tax returns; L & C Springs sought review in the United States Tax Court. The court ruled in the Commissioner's favor, and L & C Springs appealed that judgment to this court. For the reasons set forth in the following opinion, we affirm the judgment of the Tax Court.

I

BACKGROUND

A. Tax Background

When a taxpayer...

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