Court of Appeals for the Tenth Circuit June 13, 1989, 87-1159, 87-1160 (Jon R. And Carol J. Pollei, and Harry W. And Renee L. Patrick v. Commissioner of Internal Revenue)

SEYMOUR, Circuit Judge.

Petitioners John R. Pollei and Harry W. Patrick

1

appeal from the United States Tax Court’s decision upholding deficiencies assessed against their federal income tax returns for 1981. At issue is whether petitioners may deduct as “ordinary and necessary” business expenses under section 162(a) of the Internal Revenue Code, 26 U.S.C.