PLUNKETT v. C. I. R.

No. 71-1084.

465 F.2d 299 (1972)

Haldane M. PLUNKETT, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Argued December 3, 1971.

Decided July 10, 1972.


Attorney(s) appearing for the Case

Raymond J. Smith, Chicago, Ill., for petitioner-appellant; Arthur N. Nasser, Chicago, Ill., of counsel.

Fred B. Ugast, Acting Asst. Atty. Gen., Bruce I. Kogan, Gilbert E. Andrews, Elmer J. Kelsey, Attys., Tax Division, Dept. of Justice, Washington, D. C., for respondent-appellee.

Before KERNER, PELL, and SPRECHER, Circuit Judges.


PELL, Circuit Judge.

In 1968, taxpayer Haldane M. Plunkett filed two petitions in the Tax Court challenging the Commissioner's determinations regarding deficiencies in income tax, additions to tax, and alleged overpayments. The two petitions, one involving the years 1957 through 1959 and the other 1960 through 1963, were consolidated for trial and decision.1 On October 2, 1970, the Tax Court entered...

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