Tax court order finding deficiencies in the payments of income taxes is affirmed where: 1) payments to partnerships were distributions to the plaintiffs personally, and thus were not deductible as ordinary and necessary business expenses under Internal Revenue Code sec. 162 (a); and 2) the amounts of the life insurance premiums paid by the plaintiffs are not included as gross income under Internal Revenue Code section 61 (a).
Appeal from the United States Tax Court.
Argued May 29, 2009
Decided July 21, 2009
Before: LEVAL, POOLER and PARKER, Circuit Judges.
Per Curium Opinion
For Respondent: Randolph L. Hutter, United States Department of Justice, Washington, D.C.