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MUSERLIAN v. C.I.R.

No. 739, Docket 90-4053.

932 F.2d 109 (1991)

Peter E.C. MUSERLIAN, Theodora Muserlian and Peter Muserlian, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided April 23, 1991.

Attorney(s) appearing for the Case

Joseph W. Mooney, III, Clayton, Mo. (Beach, Burcke, Mooney & Lake, P.C., of counsel), for petitioners-appellants.

Bridget M. Rowan, Tax Div., Dept. of Justice, Washington, D.C. (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, Richard Farber, Tax Div., Dept. of Justice, Washington, D.C., of counsel), for respondent-appellee.

Before KEARSE, PIERCE and MINER, Circuit Judges.

MINER, Circuit Judge:

Petitioners-appellants, Peter Muserlian ("the taxpayer"), his wife Theodora Muserlian and their son, Peter E.C. Muserlian, appeal from a decision entered in the United States Tax Court (Goffe, J.) affirming the disallowance by respondent-appellee, the Commissioner of Internal Revenue ("Commissioner"), of certain deductions taken by appellants on their tax returns for the years 1981 and 1982. The Commissioner had issued a notice of deficiency...

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