Phyllis A. Woodall and Jeannie S. Coutta v. Commissioner of Internal Revenue

PATRICK E. HIGGINBOTHAM, Circuit Judge:

Phyllis Woodall and Jeannie Coutta appeal a Tax Court judgment finding additional taxes due in their 1982, 1983, and 1984 tax years. The dispute arises out of fire losses to two partnership assets presenting issues of valuation and accounting for income. We affirm.

I

Woodall and Coutta were equal partners in El Paso Cosmopolitan, a partnership operating two nightclubs, the Naked Harem Show Bar and the El Paso Cosmopolitan Topless Show Bar. On April 5, 1982, the Cosmopolitan suffered extensive fire damage. Woodall estimated the value of the partnership…