John C. Echols and Deanna O. Echols v. Commissioner of Internal Revenue

WIENER, Circuit Judge.

Petitioners, John C. Echols (Echols) and his wife, Deanna 0. Echols (collectively, Taxpayers), appeal from that portion of the decision of the United States Tax Court which held that Taxpayers were not entitled to claim a deduction in 1976 under 26 U.S.C. Section 165(a) (§ 165(a) of the Internal Revenue Code of 1954 as amended (I.R.C.) and in effect for the years at issue in this case) on the basis of abandonment. The tax court found that the Taxpayers had failed to establish that they had abandoned their partnership interest in 1976, or that the partnership had…