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UNITED STATES v. ZOLLA

No. 82-5947.

724 F.2d 808 (1984)

UNITED STATES of America, Plaintiff-Appellee, v. Edward M. ZOLLA, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided January 24, 1984.

Attorney(s) appearing for the Case

Laurie A. Snyder, Atty., Tax Div., Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Robert Wyshak, Beverly Hills, Cal., for defendant-appellant.

Before GOODWIN and TANG, Circuit Judges, and JAMESON, District Judge.

GOODWIN, Circuit Judge:

Zolla appeals a district court judgment in favor of the government in its action to reduce to judgment Zolla's federal income tax liabilities for 1968 and 1969.

Neither the government nor Zolla introduced direct evidence of Zolla's income and deductions for the years in question. The government relied upon the presumption of correctness that attaches to the IRS's determination of a tax deficiency. See Rockwell v. Commissioner,

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