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CURTIS v. C. I. R.

No. 79-1220.

623 F.2d 1047 (1980)

Stanley G. CURTIS, Petitioner-Appellant Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee Cross-Appellant.

United States Court of Appeals, Fifth Circuit.

August 13, 1980.

Attorney(s) appearing for the Case

Stanley G. Curtis, pro se.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Act. Chief, App. Section, Jonathan S. Cohen, Gilbert S. Rothenberg, Attys., Tax Div., U. S. Dept. of Justice, Lester J. Stein, Acting Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee cross-appellant.

Before GOLDBERG, GARZA and REAVLEY, Circuit Judges.

GOLDBERG, Circuit Judge:

Stanley G. Curtis brings this appeal from a decision of the Tax Court, P H Memo T.C., ¶ 78,265 (1978), and the Commissioner of Internal Revenue (Commissioner) cross-appeals. At issue are the correctness and adequacy of various findings of fact made by the Tax Court in its ruling on the case.

I.

This case originated in 1969 when the Commissioner selected Curtis' tax returns...

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