Peter E.C. Muserlian, Theodora Muserlian and Peter Muserlian v. Commissioner of Internal Revenue

MINER, Circuit Judge:

Petitioners-appellants, Peter Muserlian (“the taxpayer”), his wife Theodora Muser-lian and their son, Peter E.C. Muserlian, appeal from a decision entered in the United States Tax Court (Goffe, J.) affirming the disallowance by respondent-appellee, the Commissioner of Internal Revenue (“Commissioner”), of certain deductions taken by appellants on their tax returns for the years 1981 and 1982. The Commissioner had issued a notice of deficiency disallowing interest payment deductions taken by Peter Muserlian on various purported “loans” made to him by his five children. A…