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LOAD, INC. v. C.I.R.

No. 07-72564.

554 F.3d 785 (2009)

LOAD, INC.; COAD, Inc., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Filed February 2, 2009.

Attorney(s) appearing for the Case

John F. Daniels, Janice Procter-Murphy, Alexander Arpad, Phoenix, AZ, for the petitioners.

Richard T. Morrison, Acting Assistant Attorney General, Teresa E. McLaughlin, Kathleen E. Lyon, Washington, DC, for the respondent.

Before: MYRON H. BRIGHT, PROCTER HUG, JR., and STEPHEN REINHARDT, Circuit Judges.

OPINION

PER CURIAM:

Appellants LOAD, Inc. and COAD, Inc.1 challenge the Tax Court's determination of a federal income tax deficiency for the tax year ending September 30, 2000. The Tax Court held that certain of ADI's expenses were not deductible as ordinary and necessary business expenses under 26 U.S.C. § 162(a) and must be capitalized as inventory costs under 26 U.S.C. §...

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