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MEYER v. C. I. R.

No. 76-2101 Summary Calendar.

547 F.2d 943 (1977)

Fred G. MEYER and Bessie Meyer, Petitioners-Appellees, Cross-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant, Cross-Appellee.

United States Court of Appeals, Fifth Circuit.

February 28, 1977.

Attorney(s) appearing for the Case

Scott P. Crampton, Asst. Atty. Gen., Tax Div., Dept. of Justice, George G. Wolf, Ann Belanger Durney, Attys., Gilbert E. Andrews, Act. Chief, App. Sect., Dept. of Justice, Washington, D. C., Meade Whitaker, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellant, cross-appellee.

Theodore W. Glocker, Jr., Jacksonville, Fla., for petitioners-appellees, cross-appellants.

Before BROWN, Chief Judge, and GEWIN and MORGAN, Circuit Judges.

PER CURIAM:

After a careful and full consideration of the record and the briefs, it is our opinion that the judgment of the Tax Court should be affirmed. The memorandum opinion of the Tax Court is attached hereto as Appendix A.

APPENDIX A

MEMORANDUM OPINION

TIETJENS, Judge: The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable years 1970 and 1971 in the amounts of $25,861 and $973 respectively...

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