Jacquelyn Hayman v. Commissioner of Internal Revenue

MINER, Circuit Judge:

Petitioner-appellant Jacquelyn Hayman (“Hayman”) appeals from a decision entered April 21,1992 in the United States Tax Court (Clapp, J.) sustaining the deficiency determinations made by respondent-appellee Commissioner of Internal Revenue (“Commissioner”) and assessed jointly against her and her husband John Hayman (“John”) for the taxable years 1977, 1978 and 1979. The Hay-mans reported losses from tax shelters that substantially offset their reported income for these years. The Commissioner disallowed the deductions, finding, inter alia, that the shelters were not…