Crc Corporation v. Commissioner of Internal Revenue. Crc Corporation v. Commissioner of Internal Revenue

OPINION OF THE COURT

GIBBONS, Circuit Judge.

The Commissioner of Internal Revenue appeals from a decision of the United States Tax Court with respect to the federal income tax liability of CRC Corporation for the calendar year 1972. The taxpayer cross-appeals from that decision to the extent that it disallowed deduction of certain abandonment losses. At issue in the Commissioner’s appeal is the tax treatment of deductions by a limited partner in an oil and gas drilling partnership. The Tax Court held that the deductions taken by the taxpayer were proper under the law applicable in 1972. 1 73…