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BIGGS v. C. I. R.

Nos. 20309, 20310 and 20311.

440 F.2d 1 (1971)

Raymond A. and Joan BIGGS, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Raymond A. and Joan BIGGS, Petitioners-Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Cross-Appellant.

United States Court of Appeals, Sixth Circuit.

March 30, 1971.

Attorney(s) appearing for the Case

James F. Shea, and Frederick W. Heath, Birmingham, Mich., for Biggs; Frederick Wm. Heath, Shea, Shea, Heath & Solner, Birmingham, Mich., on brief.

Robert D. Bickel, Dept. of Justice, Washington, D. C., for commissioner; Johnnie M. Walters, Asst. Atty. Gen., Meyer Rothwacks, William Massar, Attys., Dept. of Justice, Washington, D. C., on brief.

Before BROOKS and MILLER, Circuit Judges, and O'SULLIVAN, Senior Circuit Judge.

BROOKS, Circuit Judge.

Taxpayer, an osteopathic physician and his wife, has appealed the Tax Court's determination of his tax liabilities for an eleven year period covering 1950-1957, 1959-1961. The Commissioner of Internal Revenue, following an examination of taxpayer's income tax returns and supporting records for the taxable years in question, assessed a number of tax deficiencies and penalties based upon alleged understatement of gross income and overstatement...

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