Wolverine, Ltd., Sheldon M. Sisson, a Partner Other Than Tax Matters Partner Woodchuck, Ltd., Sheldon M. Sisson, a Partner Other Than Tax Matters Partner v. Commissioner Internal Revenue Service

39 F.3d 1190 74 A.F.T.R.2d 94 -6754 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. WOLVERINE, LTD., Sheldon M. Sisson, a partner other than tax matters partner; Woodchuck, Ltd., Sheldon M. Sisson, a partner other than tax matters partner, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70367. United States Court of Appeals, Ninth Circuit. Argued and Submitted Oct. 7, 1994. Decided Oct. 24, 1994. 1 Before: FLETCHER, BOOCHEVER and FERNANDEZ, Circuit Judges 2 MEMORANDUM * 3 This is an appeal from the Tax Court's denial of a Petition for Readjustment of Partnership Items under 26 U.S.C. Sec. 6226 . See Wolverine, Ltd. v. Commissioner, 64 T.C.M. (CCH) 1342 (1992). Sheldon Sisson argues that the Tax Court erred when it refused to overrule the I.R.S.'s disallowance of certain deductions taken by the partnerships in 1983. 4 We have carefully reviewed the record and the decision of the Tax Court, and we affirm for the reasons set forth…