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DEVINE v. C. I. R.

No. 75-3979.

558 F.2d 807 (1977)

Judy DEVINE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

September 2, 1977.

Attorney(s) appearing for the Case

Ronald G. Williams, Ronald M. Mankoff, Dallas, Tex., for petitioner-appellant.

Scott P. Crampton, Asst. Atty. Gen., Michael L. Paup, Daniel F. Ross, Attys., Gilbert Andrews, Acting Chief, Appellate Section, U. S. Dept. of Justice, Mary L. Jennings, Atty., Tax Div., Meade Whitaker, Chief Counsel, I.R.S., Washington, D. C., for respondent-appellee.

Before THORNBERRY and GEE, Circuit Judges, and Markey, Chief Judge.

MARKEY, Chief Judge:

Appeal from a memorandum decision of the United States Tax Court, 34 T.C.M. (CCH) 1077 (1975), upholding income tax deficiencies levied upon taxpayer Judy Devine for 1965-67. Jurisdiction is under I.R.C. § 7482.1 We affirm.

Background

The Tax Court made extensive findings of fact, the material portions being:

Judy Devine is a single individual...

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