John A. Laney and Jeanine Laney v. Commissioner of Internal Revenue

JOHN R. BROWN, Circuit Judge:

John and Jeanine Laney appeal from a decision of the United States Tax Court upholding the Internal Revenue Service’s determination of deficiencies in their federal income tax for the tax years 1971, 1972 and 1973. The fundamental question on appeal is whether the Tax Court correctly interpreted one path of the maze of financial transactions in which the Laneys were involved as a limited partnership with recourse liabilities, so that Mrs. Laney could only deduct losses up to the amount of her adjusted basis, here $1000. Unable to term the Tax Court’s reasoning…