Jack T. Jamar Estate of Norma Jamar, Deceased, Jack T. Jamar v. Commissioner of Internal Revenue

61 F.3d 911 76 A.F.T.R.2d 95 -5751, 95-2 USTC P 50,438 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jack T. JAMAR; Estate of Norma Jamar, Deceased, Jack T. Jamar, Executor, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 92-70273. United States Court of Appeals, Ninth Circuit. Argued and Submitted Sept. 1, 1993. Decided July 20, 1995. 1 Appeal from the United States Tax Court. Tax Court 2 Reversed. 3 Before: BRUNETTI, KOZINSKI, and BOGGS, * Circuit Judges. 4 MEMORANDUM ** 5 Jack T. Jamar and the estate of his late wife appeal from the Tax Court's determination that they owed an additional income tax of $15,294 for the 1983 taxable year. This deficiency is caused by the determination of the IRS and the Tax Court that certain losses incurred in 1983 should have been allocated as the loss of taxpayers' corporate business, JNJ Oilfield Services, Inc., not a loss to the individual taxpayers. After reviewing the record, we hold that taxpayers adequately…