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HUMAN ENGINEERING INSTITUTE v. C. I. R.

No. 79-1123.

629 F.2d 1160 (1980)

HUMAN ENGINEERING INSTITUTE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Joseph S. KOPAS and Mary E. Kopas, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided August 6, 1980.

Attorney(s) appearing for the Case

Joseph S. Kopas, Cleveland, Ohio, for petitioners-appellants.

M. Carr Ferguson, Gilbert Andrews, Asst. Atty. Gen., Gary R. Allen, Mary Jennings, James F. Miller, Tax Div., U. S. Dept. of Justice, Stuart E. Seigel, Chief Counsel, I. R. S., Washington, D. C., for respondent-appellee.

Before MERRITT and JONES, Circuit Judges, and WISEMAN, District Judge.

WISEMAN, District Judge.

Taxpayers, representing Human Engineering Institute [HEI] and themselves individually, appeal the decision of the United States Tax Court, which substantially upheld the assessment by the Commissioner of the Internal Revenue Service [IRS] of income tax deficiencies and penalties. The taxpayers also appeal the denial by the Tax Court of their motion for posttrial oral argument. To describe the history...

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