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VISHNEVSKY v. UNITED STATES

No. 77-1767.

581 F.2d 1249 (1978)

John VISHNEVSKY and Margaret Vishnevsky, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 9, 1978.

Attorney(s) appearing for the Case

Sherwin C. Peltin, Milwaukee, Wis., for plaintiffs-appellants.

Francis J. Gould, Appellate Section, Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before PELL and TONE, Circuit Judges, and EAST, Senior District Judge.

PELL, Circuit Judge.

Plaintiffs-appellants John and Margaret Vishnevsky (taxpayers) are husband and wife who filed joint federal income tax returns for the years 1965 through 1970. Having apparently audited their returns, the Internal Revenue Service issued a statutory notice of deficiency for the years 1966, 1967, 1969, and 1970. The notice was by letter of July 10, 1972, signed by W. S. Stumpf, District Director of Internal Revenue, on behalf of Johnnie M. Walters...

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