Paul S. Mosesian Diane M. Mosesian v. Commissioner of Internal Revenue

967 F.2d 588 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Paul S. MOSESIAN; Diane M. Mosesian, Petitioner-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 91-70058. United States Court of Appeals, Ninth Circuit. Argued and Submitted Feb. 12, 1992. Decided May 29, 1992. Before GOODWIN, FARRIS and POOLE, Circuit Judges. 1 MEMORANDUM * I. OVERVIEW 2 Paul Mosesian, a lawyer/business person, and his wife Diane Mosesian, (taxpayers) appeal from the U.S. Tax Court's holding that their investments in wind turbines lacked economic substance and could not form the basis for tax deductions or credits. The taxpayers also appeal: 1) their penalties for negligence under I.R.S. Code section 6653(a), and for underpayment of taxes attributable to a valuation overstatement under section 6659; 2) the imposition of increased interest rates on their substantial underpayment of taxes attributable to a tax motivated transaction under section 6621(c); and 3) their…