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BEECHER v. C.I.R.

No. 05-71894.

481 F.3d 717 (2007)

Gary BEECHER; Delores Beecher, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed March 23, 2007.

Attorney(s) appearing for the Case

Edward B. Simpson, San Francisco, CA; John Gigounas, San Francisco, CA, for the petitioners-appellants.

Eileen J. O'Connor, Assistant Attorney General, Washington, D.C.; Kenneth L. Greene, Tax Division, Department of Justice, Washington, D.C.; Deborah K. Snyder, Tax Division, Department of Justice, Washington, D.C., for the respondent-appellee.

Before RONALD M. GOULD and MILAN D. SMITH, JR., Circuit Judges, and ALFRED V. COVELLO, District Judge.

COVELLO, District Judge.

This is an appeal from a decision of the United States Tax Court upholding a tax deficiency determination of the Commissioner of Internal Revenue ("Commissioner").1 It is brought pursuant to Internal Revenue Code § 7482.2 The appellants, Gary Beecher and Dolores Beecher ("Beechers") challenge the tax court's ruling that the Beechers cannot apply losses from their various rental...

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