Estate of Sydney S. Baron, Sylvia S. Baron, Administratrix, and Sylvia S. Baron v. Commissioner of Internal Revenue

PIERCE, Circuit Judge:

This is an appeal from a judgment of the United States Tax Court, Tannenwald, Judge, holding that taxpayers Sydney S. Baron (“Baron”), now deceased, and his wife improperly claimed certain deductions on their joint personal income tax return for the tax years 1977 and 1978 and must therefore pay $230,031 and $82,525 for those years, respectively, pursuant to a notice of deficiency issued by the Commissioner of Internal Revenue (“Commissioner”). The claimed deductions reflected alleged losses relating to certain rights in a master recording of the soundtrack to a movie.…