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OWENS v. C. I. R.

No. 76-1159.

568 F.2d 1233 (1977)

E. Keith OWENS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 20, 1977.

Attorney(s) appearing for the Case

Frank G. Pollock, Bloomfield Hills, Mich., Robert L. Schwartz, Dickinson, Wright, McKean, Cudlip & Moon, Detroit, Mich., for petitioner-appellant.

Michael L. Paup, Scott P. Crampton, Gilbert Andrews, Asst. Attys. Gen., Tax Div., U. S. Dept. of Justice, Washington, D. C., Jonathan S. Cohen, Stephen M. Gelber, Meade Whitaker, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before PHILLIPS, Chief Judge, PECK, Circuit Judge, and GREEN, District Judge.

PECK, Circuit Judge.

Petitioner-appellant taxpayer perfected this appeal from a judgment of the Tax Court, which held that the taxpayer was liable for income tax deficiencies for the calendar years 1964 and 1965. The full Tax Court reviewed the case, and the judges split six to four, one not participating, in upholding respondent-appellee Commissioner's determination. Owens v. Commissioner, 64 T.C....

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