Durand A. HOLLADAY and Blanche F. Holladay, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Fifth Circuit. Unit Bhttps://leagle.com/images/logo.png
July 9, 1981.
July 9, 1981.
Attorney(s) appearing for the Case
Kenneth G. Anderson, Jacksonville, Fla., for petitioners-appellants.
M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Act. Chief, Appellate Section, Tax Div., Dept. of Justice, N. Jerold Cohen, Chief Counsel, Internal Revenue Service, Michael L. Paup, Jonathan S. Cohen, Daniel F. Ross, Tax Division, Dept. of Justice, Washington, D.C., for respondent-appellee.
Before HILL, and FRANK M. JOHNSON, Jr., Circuit Judges, and SCOTT, District Judge.
United States Court of Appeals, Fifth Circuit. Unit B
FRANK M. JOHNSON, Jr., Circuit Judge:
Durand A. Holladay1 petitioned the United States Tax Court for a review of the federal income tax deficiencies totalling $589,396 assessed against him by the Commissioner of Internal Revenue for calendar years 1971 through 1973.2 Holladay appeals from the Tax Court's decision in favor of the Commissioner under 26 U.S.C.A. § 7482. This case was consolidated for oral...
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