Paul P. Brountas v. Commissioner of Internal Revenue, Paul P. And Lynn T. Brountas v. Commissioner of Internal Revenue

BREYER, Circuit Judge.

In this “tax shelter” case, we are asked to determine the propriety of certain deductions taken by a limited partner in an oil- and-gas drilling partnership. There is little question that subsequent changes in the law have made deductions similar to those at issue here improper for individual taxpayers. See 26 U.S.C. § 465 (Supp. IV 1980) (the “at risk” provisions). But, under the law as it stood when the deductions were taken, which is the law we must apply, the propriety of the deductions is a complicated and unsettled question. The Tax Court’s opinion from which this…