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CARBINE v. C.I.R.

No. 85-3061.

777 F.2d 662 (1985)

John D. CARBINE and Eleanor W. Carbine, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

December 6, 1985.

Attorney(s) appearing for the Case

Harry K. Mansfield, R.K. Gad, III, Boston, Mass., for petitioners-appellants.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Chief, Richard Farber, John Dudeck, Attys., Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before RONEY and ANDERSON, Circuit Judges, and MORGAN, Senior Circuit Judge.

ANDERSON, Circuit Judge:

Appellants John D. and Eleanor W. Carbine ("Carbine") challenge the decision of the Tax Court, 83 T.C. 356, in favor of the Commissioner of Internal Revenue ("Commissioner") finding them liable for tax deficiencies for the years 1977 and 1978. The issue before us is whether Carbine may deduct premiums paid with respect to an insurance policy on the life of John Carbine. We affirm the decision of the Tax Court...

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