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  5. 639 F.2d 805 (1981)
 

BREWIN v. C. I. R.

Nos. 79-2433, 79-2510.

639 F.2d 805 (1981)

Roger C. BREWIN and Mary T. Brewin, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Kurt H. and Jolanda M. TEIL, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided January 21, 1981.

Attorney(s) appearing for the Case

Murray J. Belman, Washington, D. C., for appellants.

R. Bruce Johnson, Atty., Dept. of Justice, Washington, D. C., with whom M. Carr Ferguson, Asst. Atty. Gen. and Richard Farber, Atty., Dept. of Justice, Washington, D. C., were on the brief, for appellee; Michael L. Paup, Atty., Dept. of Justice, Washington, D. C., also entered an appearance for appellee.

Before ROBINSON and MacKINNON, Circuit Judges and JUNE L. GREEN, United States District Judge for the District of Columbia.

Opinion for the court filed by District Judge JUNE L. GREEN.

JUNE L. GREEN, District Judge:

This is an appeal from the determinations by the Tax Court upholding the Commissioner's assessment of income tax deficiencies against taxpayers, Kurt Teil and Roger Brewin, for the years 1972 and 1971, respectively. Teil v. Commissioner, 72 T.C. 841 (1979), (hereinafter Teil); Brewin v. Commissioner, 72 T.C. 87 (September...

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