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DEASON v. C. I. R.

No. 76-4162.

590 F.2d 1377 (1979)

Dorris H. DEASON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 12, 1979.

Attorney(s) appearing for the Case

Earnest N. Deason, Birmingham, Ala., for petitioner-appellant.

Dorris H. Deason, pro se.

Myron C. Baum, Acting Asst. Atty. Gen., Gilbert E. Andrews, Act. Chief, Appellate Section, U. S. Dept. of Justice, Washington, D. C., Meade Whitaker, Chief Counsel, Internal Revenue Service, Washington, D. C., Jonathan S. Cohen, James S. Maxwell, Attys., David Pincus, Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before MORGAN, RONEY and VANCE, Circuit Judges.

MORGAN, Circuit Judge:

This is an appeal from a judgment of the Tax Court against the taxpayer. The Commissioner determined that the taxpayer, Dorris H. Deason, had understated her tax liability for the year 1969. He assessed her for a deficiency and for the five percent penalty authorized by I.R.C. § 6653(a)1 in cases in which the underpayment "is due to negligence or intentional disregard of rules and regulations."

The deficiency...

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