United States Fifth Circuit

Tax Court properly denied taxpayers a deduction under 26 U.S.C. section 165 for their initial investments in partnerships, but imposition of an increased interest rate under 26 U.S.C. section 6621(c) was improper where no deduction was disallowed under 26 U.S.C. section 183, and no alternative basis for imposing the rate was proffered.

Appellate Information

• Decided 05/13/2002
• Published 05/13/2002

Judges

• WIENER, Circuit Judge:, Before JONES, WIENER, and PARKER, Circuit Judges.

Court

• United States Fifth Circuit

Counsel

• For Appellant:
  
• J. Grant Coleman (argued), Len R. Brignac, King, LeBlanc & Bland, New Orleans, LA, for Alvin and Patty Copeland., Kenneth W. Rosenberg (argued), U.S. Dept. of Justice, Tax Div., Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Charles Casazza, Clerk, U.S. Tax Court, Richard W. Skillman, Internal Revenue Service, Washington, DC, for C.I.R., Thomas E. Redding (argued), Sallie W. Gladney, Teresa Jean Womack, Redding & Associates, Houston, TX, for Cummings, Amicus Curiae.