Guy B. Bailey, Jr., Lois M. Bailey, Bernard B. Neuman, and Miriam Neuman v. Commissioner of Internal Revenue

KEARSE, Circuit Judge:

Petitioners Guy B. Bailey, Jr., Lois M. Bailey, Bernard B. Neuman, and Miriam Neuman (collectively “taxpayers”) appeal from final decisions of the United States Tax Court, Irene F. Scott, Judge, finding deficiencies in their income taxes for certain years during the period 1973-1976. The tax court, following a remand from this Court on taxpayers’ prior appeal, Bailey v. Commissioner, 912 F.2d 44 (2d Cir.1990) (“Bailey I”), ruled that nonrecourse notes used to purchase certain motion picture rights should be disregarded for income tax purposes and hence that related…