BOYNTON v. COM'R OF INTERNAL REVENUE

No. 80-5069.

649 F.2d 1168 (1981)

Joe T. BOYNTON and Helen J. Boynton, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit. Unit B

July 9, 1981.


Attorney(s) appearing for the Case

Rogers & Meisel, Robert O. Rogers, David S. Meisel, Palm Beach, Fla., for petitioners-appellants.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Acting Chief, Appellate Sect., Richard W. Perkins, Daniel F. Ross, Attys., Tax Div., U. S. Dept. of Justice, N. Jerold Cohen, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before HILL, and FRANK M. JOHNSON, Jr., Circuit Judges, and SCOTT, District Judge.


FRANK M. JOHNSON, Jr., Circuit Judge:

Joe T. Boynton1 petitioned the United States Tax Court for a redetermination of federal income tax deficiencies totalling $203,487 assessed against him by the Commissioner of Internal Revenue [Commissioner] for calendar years 1971 through 1974.2 The Tax Court, 72 T.C. 1147, found for the Commissioner and we consider Boynton's appeal under...

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