Charles W. IRELAND and Carolyn P. Ireland, Plaintiffs-Appellants,
v.
UNITED STATES of America, Defendant-Appellee.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
July 15, 1980.
July 15, 1980.
Attorney(s) appearing for the Case
W. Bew White, Jr., Warren B. Lightfoot, Judith T. Veal, Birmingham, Ala., for plaintiffs-appellants.
M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Chief, App. Sec., Gary R. Allen, Philip I. Brennan, Donald B. Susswein, Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellee.
Before AINSWORTH and GEE, Circuit Judges, and HUNTER, District Judge.
United States Court of Appeals, Fifth Circuit.
AINSWORTH, Circuit Judge:
Appellant Charles W. Ireland1 ("Ireland") used aircraft provided by his company to travel between his home and the firm's headquarters. The Internal Revenue Service ("IRS") assessed additional income to Ireland in the amount of the alleged value of the plane rides. After paying the resulting deficiency, Ireland brought suit in district court seeking a refund. The district court upheld the assessment and denied...
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