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DENISON v. C. I. R.

No. 82-1272.

689 F.2d 771 (1982)

Cleo Stephens DENISON, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided October 4, 1982.

Attorney(s) appearing for the Case

Cleo Stephens Denison, pro se.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Richard W. Perkins, Philip I. Brennan, Attys., Tax Division Dept. of Justice, Washington, D. C., for appellee.

Before HEANEY and BRIGHT, Circuit Judges, and HENLEY, Senior Circuit Judge.

PER CURIAM.

Cleo Stephens Denison appeals from an order by the tax court sustaining an assessment of federal income tax deficiency and additions. After Denison failed to file a federal income tax return for the taxable year 1977, the Commissioner determined a deficiency by averaging the gross profits for the preceding two years (1975 and 1976) from Denison's masonry contracting business. Although Denison produced no supporting business records for the year 1977, he...

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