Jonas R. Bryant, Carmen L. Bryant v. Commissioner of Internal Revenue

JOHN W. PECK, Senior Circuit Judge.

Taxpayers Jonas and Carmen Bryant appeal from a judgment of the Tax Court finding deficiencies in income tax for calendar years 1979 and 1982. 1 These deficiencies resulted from the Tax Court’s finding that (1) the taxpayer could not deduct certain funds expended in 1979 for development of the Austin Silver Mine because the funds were the proceeds of a promissory note for which he was not at risk of real economic loss under Section 465; (2) the taxpayers’ 1982 investment in the Summit Gold Mine lacked economic substance; and (3) the taxpayers failed to prove…