Lewis Arthur Merryman v. Commissioner of Internal Revenue, Michael A. Carroll and Margaret W. Carroll v. Commissioner of Internal Revenue

EDITH H. JONES, Circuit Judge:

Appellants Lewis Arthur Merryman, Michael A. Carroll, and Margaret W. Carroll contest federal income tax deficiencies for the calendar year 1980. The Commissioner of Internal Revenue disallowed these petitioners’ deductions and investment tax credits attributable to their respective proportionate interests in the Keeman Company (“Keeman”), a Louisiana general partnership. The Tax Court concluded that the Keeman partnership lacked economic substance and should be disregarded for tax purposes.. We do not find the conclusion clearly erroneous, hence we affirm.

*880BACKGRO…