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M. H. S. CO., INC. v. C. I. R.

No. 76-2185.

575 F.2d 1177 (1978)

M. H. S. COMPANY, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 15, 1978.

Attorney(s) appearing for the Case

Boyd L. Rhodes, Jr., Heiskell, Donelson, Adams, Williams & Kirsch, Lewis R. Donelson, III, Donald A. Malmo, Charles T. Tuggle, Jr., Memphis, Tenn., for petitioner-appellant.

Scott P. Crampton, Asst. Atty. Gen., Gilbert Andrews, Myron C. Baum, Jonathan S. Cohen, Meade Whitaker, Murray Horwitz, Tax. Div., U. S. Department of Justice, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before PHILLIPS, Chief Judge, and CELEBREZZE and KEITH, Circuit Judges.

PER CURIAM.

This is an appeal from the decision of the United States Tax Court involving federal income tax deficiencies for the years ending September 30, 1966, 1967, 1969 and 1970 in the amounts of $19,444.52, $62.13, $996.50 and $977.16, respectively. Reference is made to the comprehensive findings of fact and opinion of Judge Irene F. Scott, reported at 35 T.C.M. 733 (1976), for a recitation of pertinent facts.

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