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CORNELIUS v. C. I. R.

No. 73-1005.

494 F.2d 465 (1974)

Paul G. CORNELIUS et al., (Mary M. Cornelius as Executrix of the Estate of Paul G. Cornelius, Deceased, substituted instead of and in place of Paul G. Cornelius), Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

May 16, 1974.

Attorney(s) appearing for the Case

Martin J. Nash, Miami, Fla., Vernon W. Turner, Homestead, Fla., for petitioners-appellants.

Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Atty., Tax Div. U. S. Dept. of Justice, Lee H. Henkel, Jr., Chief Counsel, Raymond W. Sifly, Atty., I. R. S., Washington, D. C., Henry C. Stockell, Jr., Regional Counsel, Marlene Gross, I. R. S., Miami, Fla., Murray S. Horwitz, Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before TUTTLE, BELL and GOLDBERG, Circuit Judges.

GOLDBERG, Circuit Judge:

Appellant taxpayers, Paul G. Cornelius, Sr. and his wife Mary M. Cornelius, and Jack H. Cornelius (a son of Paul G. Cornelius, Sr.) and his wife Betty J. Cornelius, appeal from a decision of the United States Tax Court declaring that taxpayers were deficient in their income tax payments for taxable year 1967 in the amounts of $59,525.71 and $27,877.72, respectively.1 This...

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