Court of Appeals for the Ninth Circuit January 23, 1990, 87-7377 (Marcus W. Melvin and Marilyn E. Melvin v. Commissioner of Internal Revenue Service)

PER CURIAM:

Marcus Melvin appeals the Tax Court’s partial disallowance of a deduction for a bad partnership loan. The Tax Court held that Melvin was “at risk” for, and therefore could deduct under 26 U.S.C. § 465, only for his pro rata share of the loan.