DELANEY v. C.I.R.

No. 83-7627.

743 F.2d 670 (1984)

Ernest N. DELANEY and Marjorie M. Delaney, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 21, 1984.


Attorney(s) appearing for the Case

Ernest Delaney, in pro per.

John P. Griffin, Atty., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before KENNEDY, SKOPIL, and NELSON, Circuit Judges.


KENNEDY, Circuit Judge:

The Tax Court affirmed the IRS's determination that $43,000 in Swiss gold coins and $305 in unexplained bank deposits constituted unreported income. The Delaneys now appeal, challenging the assessment of a deficiency and a negligence penalty pursuant to 26 U.S.C. § 6653(a). We affirm.

The Commissioner's deficiency determination is entitled to a presumption of correctness "once some substantive evidence is introduced demonstrating...

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