Edward N. Gomberg and Helen E. Gomberg v. Commissioner, Internal Revenue Service

WELLFORD, Circuit Judge.

Petitioners-appellants, Edward and Helen Gomberg, appeal the United States Tax Court decision in Patin v. Commissioner, 88 T.C. 1086 (1987), upholding the Commissioner of the Internal Revenue Service’s disallowance of a $120,000 deduction from the Gombergs’ 1980 gross income in connection with a gold and silver mine investment. Gomberg also challenges the assessment of an interest penalty for tax motivated transactions and a negligence penalty. See I.R.C. § 6621 (1986) (interest penalty on tax motivated transactions) (revised by T.R.A.1986); I.R.C. § 6653(a) (1986)…