Kermit and Betty Uecker, Ann Uecker, Jon and Sheridan Hansen v. Commissioner of Internal Revenue
This text of 766 F.2d 909 (Kermit and Betty Uecker, Ann Uecker, Jon and Sheridan Hansen v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
Without regard to the tax court's analysis of whether the federal grazing privileges are leases or licenses, the decision of the tax court, 81 T.C. 983, is affirmed on the basis of that court’s analysis of 26 U.S.C. § 178. Section 178 does not permit the claimed deductions as to privileges or leases such as those involved here which the proof showed could be renewed indefinitely.
AFFIRMED.
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766 F.2d 909, 56 A.F.T.R.2d (RIA) 5690, 1985 U.S. App. LEXIS 20653, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kermit-and-betty-uecker-ann-uecker-jon-and-sheridan-hansen-v-ca5-1985.