Copeland v. Commissioner

WIENER, Circuit Judge:

Petitioners-Appellants Alvin C. Copeland and Patty K. Copeland, also known as Patty K. White (collectively, “Taxpayers”) appeal the Tax Court’s grant of partial summary judgment to the Commissioner of Internal Revenue (“Commissioner”) and the Tax Court’s denial of their motion for summary judgment. We conclude that the Tax Court properly denied the Taxpayers’ deduction under 26 U.S.C. § 165 (“I.R.C. § 165”) for their initial investments in the partnerships, and therefore affirm that ruling. The Tax Court erred, however, in sustaining the Commissioner’s imposition of the…