Leonard Gordon, Plaintiff-appellant, v. United States of America, Defendant-appellee, 82 F.3d 422 (9th Cir. 1996)
Annotate this CaseBefore: GOODWIN, WIGGINS, and O'SCANNLAIN, Circuit Judges.
MEMORANDUM**
Taxpayers Leonard and Chandra Gordon appeal the district court's summary judgment in favor of the United States in the Gordon's action alleging that the Internal Revenue Service improperly denied their claim for an income tax refund when it disallowed their claimed loss based on an economic downturn as an impermissible deduction under 26 U.S.C. § 165.
For the reasons stated in the district court's order granting summary judgment, we affirm. See Pack v. United States, 992 F.2d 955, 958 (9th Cir. 1993); Boyd v. United States, 762 F.2d 1369, 1371 (9th Cir. 1985) (administrative claim must be exactly like theory of recovery presented to district court).
AFFIRMED.
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