Kermit and Betty Uecker, Ann Uecker, Jon and Sheridan Hansen v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Fifth Circuit
Kermit and Betty Uecker, Ann Uecker, Jon and Sheridan Hansen v. Commissioner of Internal Revenue, 766 F.2d 909 (5th Cir. 1985)
56 A.F.T.R.2d (RIA) 5690; 1985 U.S. App. LEXIS 20653
Kermit and Betty Uecker, Ann Uecker, Jon and Sheridan Hansen v. Commissioner of Internal Revenue
Opinion
Without regard to the tax court's analysis of whether the federal grazing privileges are leases or licenses, the decision of the tax court, 81 T.C. 983, is affirmed on the basis of that court’s analysis of 26 U.S.C. § 178. Section 178 does not permit the claimed deductions as to privileges or leases such as those involved here which the proof showed could be renewed indefinitely.
AFFIRMED.
Reference
- Full Case Name
- Kermit and Betty UECKER, Ann Uecker, Jon and Sheridan Hansen, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
- Cited By
- 8 cases
- Status
- Published