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AKLAND v. C.I.R.

No. 84-7009.

767 F.2d 618 (1985)

Olaf C. AKLAND, and Bertha A. Akland, et al., Petitioners/Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent/Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 31, 1985.

Attorney(s) appearing for the Case

John R. Bernard, Bernard & Pinatelli, San Francisco, Cal., for petitioners, appellants.

William A. Whitledge, U.S. Dept. of Justice, Washington, D.C., for respondent, appellee.

Before FLETCHER, BOOCHEVER, and NORRIS, Circuit Judges.

BOOCHEVER, Circuit Judge:

Taxpayers appeal the Tax Court's finding of deficiencies for the years 1976 through 1979 and its imposition of penalties for fraud. We affirm both the findings of deficiency and the penalties.

I. BACKGROUND

Olaf and Bertha Akland, together with their son and daughter-in-law Curtis and Arden Akland, (the Aklands) own a business that sells and services irrigation systems (the corporation).

In 1976, the Aklands...

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