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FRIERDICH v. C.I.R.

No. 89-3794.

925 F.2d 180 (1991)

Michael V. FRIERDICH and Connie J. Frierdich, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 12, 1991.

Attorney(s) appearing for the Case

Michael V. Frierdich and Connie J. Frierdich, Columbia, Ill., pro se.

Arthur W. Morris, Frierdich, Lopinot & Morris, Columbia, Ill., for petitioners-appellants.

Peter K. Scott, I.R.S., Gary R. Allen, Jordan L. Glickstein, William S. Estabrook, Dept. of Justice, Tax Div., Appellate Section, and Charles S. Casazza, U.S. Tax Court, Washington, D.C., for respondent-appellee.

Before POSNER, MANION, and KANNE, Circuit Judges.

MANION, Circuit Judge.

Petitioner-appellant Michael V. Frierdich and his wife Connie ("Frierdich") petitioned the United States Tax Court for a redetermination of a federal income tax deficiency assessed against them by the Internal Revenue Service ("IRS"). The IRS claimed unpaid taxes on $100,000 that Frierdich should have included in his taxable gross income for the year 1980. Frierdich (an attorney) insists that the $100,000 in question was a loan from a client...

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