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WILLIS v. C.I.R.

No. 83-1622.

736 F.2d 134 (1984)

Gordon C. WILLIS and Jean H. Willis, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided June 7, 1984.

Attorney(s) appearing for the Case

Robert J. Tyrrell, Bethesda, Md. (Ash, Bauersfeld, Burton, Hendricks & Tyrrell, Bethesda, Md., on brief), for appellants.

Lisa A. Prager, Tax Div., Dept. of Justice, Washington, D.C. (Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Ann Belanger Durney, Tax Div., Dept. of Justice, Washington, D.C., on brief), for appellee.

Before WINTER, Chief Judge, WIDENER, Circuit Judge, and PECK, Senior Circuit Judge.

JOHN W. PECK, Senior Circuit Judge:

Gordon C. Willis (Taxpayer) brings this appeal from an adverse decision of the United States Tax Court. He challenges the court's finding of a deficiency in his 1976 federal income tax return (tax return) and its direction to pay an addition to tax according to § 6651(a)(1) of the Internal Revenue Code of 19541 (IRC) due to his late filing of the return.

In April, 1976, Charles Caveness...

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