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TAPPER v. C.I.R.

No. 84-7682.

766 F.2d 401 (1985)

Norman B. TAPPER and Eileen Tapper, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 12, 1985.

Attorney(s) appearing for the Case

E. Paul Husband, Los Angeles, Cal., for petitioners-appellants.

Martha Brissette, Dept. of Justice, Washington, D.C., for respondent-appellee.

Before PREGERSON and ALARCON, Circuit Judges, and SOLOMON, District Judge.

PER CURIAM:

Taxpayers appeal the tax court's denial of their motion for summary judgment and from the entry of stipulated decisions against them. We affirm.

Facts

Appellants, husband and wife, timely filed joint tax returns for the years 1976 and 1977. On these returns, they claimed deductions for losses on coal lease investments.

In October, 1979, and again in October, 1981, the IRS informed appellants that the companies in which...

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