Joe T. Boynton and Helen J. Boynton v. Commissioner of Internal Revenue

FRANK M. JOHNSON, Jr., Circuit Judge:

Joe T. Boynton 1 petitioned the United States Tax Court for a redetermination of federal income tax deficiencies totalling $203,487 assessed against him by the Commissioner of Internal Revenue [Commissioner] for calendar years 1971 through 1974. 2 The Tax Court, 72 T.C. 1147, found for the Commissioner and we consider Boynton’s appeal under 26 U.S.C.A. § 7482. This appeal and that of Holladay v. Commissioner, 649 F.2d 1176 (5th Cir. 1981) (consolidated for oral argument and decided the same day) both involve the propriety of allocating all of the losses…