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KENNEDY v. C. I. R.

Nos. 80-1244, 80-1245.

671 F.2d 167 (1982)

James D. KENNEDY, Jr. and Dorothy H. Kennedy, Petitioners-Appellants, and Cherokee Warehouses, Inc., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided February 4, 1982.

Attorney(s) appearing for the Case

William L. Taylor, Jr., Fred H. Moore, Robert G. Russell, Spears, Moore, Rebman & Williams, Chattanooga, Tenn., for petitioners-appellants.

N. Jerold Cohen, Chief Counsel, I. R. S., M. Carr Ferguson, Asst. Atty. Gen., Michael L. Paup, Gary R. Allen, George L. Hastings, Jr., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before WEICK and JONES, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

WEICK, Circuit Judge.

Petitioners-Appellants have appealed from the decisions of the Tax Court finding them to be liable for deficiencies in their income tax returns for the taxable years 1973 and 1974. The Tax Court's decisions are reported at 72 T.C. 793 (1979).

In Appeal No. 80-1245, the issue before us is whether the entire amounts paid by appellant Cherokee Warehouses, Inc. to...

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