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ZACK v. COMMISSIONER OF INTERNAL REVENUE

No. 82-1250.

692 F.2d 28 (1982)

Sanford S. ZACK, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

October 29, 1982.

Attorney(s) appearing for the Case

David J. Lieberman, Southfield, Mich., for petitioner-appellant.

Kenneth W. Gideon, Chief Counsel, Internal Revenue Service, George M. Sellinger, Glenn Archer, Michael L. Paup, Carlton D. Powell, Farley P. Katz, Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before MARTIN, Circuit Judge, BROWN, Senior Circuit Judge, and BERTELSMAN, District Judge.

ORDER

Sanford S. Zack seeks review of a Tax Court judgment** upholding tax deficiencies and fraud penalties assessed by the IRS. Specifically, Zack claims that the Tax Court misallocated the burden of proof by requiring the taxpayer to prove that he actually paid certain deductible expenses.

The facts of this case are fully set out in the Tax Court's opinion and the briefs of the parties. Inasmuch as those facts are not in dispute...

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