John R. Hudspeth v. Commissioner of Internal Revenue, Roger Hudspeth and Jamie Hudspeth v. Commissioner of Internal Revenue, Ronald J. Hudspeth and Jane Hudspeth v. Commissioner of Internal Revenue

509 F.2d 1224 75-1 USTC P 9224 John R. HUDSPETH, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Roger HUDSPETH and Jamie Hudspeth, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Ronald J. HUDSPETH and Jane Hudspeth, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Nos. 73--1966 to 73--1968. United States Court of Appeals, Ninth Circuit. Jan. 28, 1975. 1 Herman Simon (argued), New York City, for petitioners-appellants. 2 Alfred S. Lombardi (argued), Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee. 3 Before CHAMBERS and HUFSTEDLER, Circuit Judges, and SOLOMON, * District Judge. OPINION SOLOMON, District Judge: 4 Taxpayers 1 in these three cases, which were consolidated for trial, appeal from an adverse decision of the Tax Court of the United States. The Tax Court decision affirmed the determination of the Commissioner of Internal Revenue (Commissioner) that the taxpayers owed income tax deficiencies for 1966 of more than $3,500. The Tax Court held that they were not entitled to interest deductions under Section 163(a) of the Internal Revenue Code of 1954.…