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DREY v. UNITED STATES

No. 82-1627.

705 F.2d 965 (1983)

Leo A. DREY; Kay K. Drey, Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided February 24, 1983.

Rehearing Denied March 23, 1983.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Robert A. Bernstein, Philip I. Brennan, Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellee; Thomas E. Dittmeier, U.S. Atty., St. Louis, Mo., of counsel.

Hugh R. Law, Charles A. Lowenhaupt, St. Louis, Mo., for appellants; Lowenhaupt, Chasnoff, Freeman, Armstrong & Mellitz, St. Louis, Mo., of counsel.

Before HEANEY, McMILLIAN and ARNOLD, Circuit Judges.

PER CURIAM.

Taxpayers Leo A. Drey and his wife, Kay K. Drey, appeal from a final judgment entered in the District Court1 for the Eastern District of Missouri denying their claim against the United States for refund of additional tax and interest paid pursuant to an Internal Revenue Service (IRS) deficiency assessment. For reversal the taxpayers argue that the IRS undervalued certain real property donated by the taxpayers for purposes of...

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