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SCHIFF v. COMMISSIONER OF INTERNAL REVENUE

Cal. No. 439, Docket 84-4082.

751 F.2d 116 (1984)

Irwin SCHIFF, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided December 20, 1984.

Attorney(s) appearing for the Case

Benson A. Snaider, New Haven, Conn., for petitioner-appellant.

Raymond Hepper, Tax Division, Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup and Ann Belanger Durney, Attys., Tax Division, Dept. of Justice, Washington, D.C., of counsel), for respondent-appellee.

Before TIMBERS, VAN GRAAFEILAND and PIERCE, Circuit Judges.

PER CURIAM:

Irwin Schiff appeals from an order of the United States Tax Court (Hamblen, J.) which dismissed his petition for redetermination of income tax deficiencies for the years 1974 and 1975 and upheld the Commissioner's assessment of additions to tax for failure to pay estimated tax, 26 U.S.C. § 6654, and fraudulent underpayment, id. § 6653(b).

Appellant essentially urges this Court to...

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