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CHANIK v. C. I. R.

Nos. 73-1385-86.

492 F.2d 1182 (1974)

John CHANIK and Betty Chanik, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Sixth Circuit.

Decided February 4, 1974.

Attorney(s) appearing for the Case

Bruce H. Seyburn, Southfield, Mich., for petitioners; Donald G. Schiff, David J. Lieberman, Southfield, Mich., on brief.

Robert S. Watkins, Tax Div., Dept. of Justice, Washington, D. C., for respondent; Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Jonathan S. Cohen, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief; Lee H. Henkel, Jr., Chief Counsel, I. R. S., Washington, D. C., of counsel.

Before PHILLIPS, Chief Judge, and EDWARDS and LIVELY, Circuit Judges.

PER CURIAM.

Mr. and Mrs. John Chanik appeal from an adverse decision of the Tax Court, T.C. Memo. 1972-174.

The consolidated cases involve asserted deficiencies and penalties with respect to federal income taxes for the taxable years 1958, 1959, 1960, 1961, 1964 and 1965, in the aggregate amount of $151,435.70.

The taxpayers filed joint returns for all the years in question. The appeal involves income found to...

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