Legal Opinion
James P. Thomas and Mary Lou Thomas v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided June 6, 1986No. 85-1954PublishedCited by 133 opinions
1Opinion of the Court
BUTZNER, Senior Circuit Judge:
The Tax Court held that the Wise County Mining Program was not organized with the primary objective of making a profit. Therefore, James P. Thomas and Mary Lou Thomas (taxpayers) could not deduct their share of the program’s losses pursuant to I.R.C. §§ 162(a) and 616(a). * Accordingly, the court upheld the Commissioner’s assessment of a deficiency in the taxpayers’ 1978 income tax return. We affirm.
I
The facts in this case are fully set forth in the Tax Court’s opinion. See Thomas v. Commissioner, 84 T.C. 1244, 1245-67 (1985). They may be summarized for purposes…
2Cases cited10 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- Flowers v. CommissionerUnited States Tax Court · 1983
- Surloff v. CommissionerUnited States Tax Court · 1983
5 more not listed; retrieve them via the Exa API.
3Cited by133 opinions
- Rose v. CommissionerUnited States Tax Court · 1987
- Patin v. CommissionerUnited States Tax Court · 1987
- Don A. Brawner v. City of Richardson, Texas, L.F. Eudy, Richardson Police Department Director, and Kenneth Yarbrough, Chief of PoliceCourt of Appeals for the Fifth Circuit · 1988
- David G. Collins Pamela Collins Bernie Gates Maureen Gates Anne Hamsley and David Dister v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
128 more not listed; retrieve them via the Exa API.