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STRATTON v. C. I. R.

No. 24808.

448 F.2d 1030 (1971)

Bruce Cornwall and Louise B. STRATTON, Plaintiffs-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

September 1, 1971.

Attorney(s) appearing for the Case

Clay G. Diamos (argued), Tucson, Ariz., for appellants.

Bennet Hollander (argued), Dept. of Justice; K. Martin Worthy, Chief Counsel, Internal Rev. Service; Johnnie M. Walters, Asst. Atty. Gen., Tax Division, Washington, D. C., for appellee.

Before BARNES, BROWNING and TRASK, Circuit Judges.

TRASK, Circuit Judge:

This is an appeal from a determination by the Tax Court upholding the Commissioner's assessment of income tax deficiencies against taxpayers (husband and wife) for the years 1962 and 1963 in the amounts of $561.72 and $415.00, respectively. The Tax Court's opinion is reported at 52 T.C. 378 (1969). This court has jurisdiction of the appeal under 26 U.S.C. § 7482.

Taxpayer Bruce Cornwall Stratton is...

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