Lyle S. Simonson and Donna Simonson v. United States

LAY, Chief Judge.

Taxpayers Lyle and Donna Simonson appeal an order of the district court 1 granting summary judgment in favor of the United States and denying the Simonsons’ cross motion for summary judgment. We affirm.

Facts

Taxpayers worked at the American Crystal Sugar plant in Moorhead, Minnesota from the mid-1970’s through 1980. In December of 1979, the Simonsons purchased a semi-truck and trailer from a trucker who hauled grain between Mahnomen, Minnesota and Duluth, Minnesota. The truck and trailer were ready to be placed into service on the date of purchase. Although taxpayers had never…