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STOVALL v. C.I.R.

No. 84-5223.

762 F.2d 891 (1985)

Rawlin L. STOVALL, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

June 6, 1985.

Attorney(s) appearing for the Case

Lorraine Woods, Chicago, Ill., for plaintiff-appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., Michael L. Paup, Chief, Appellate Section, Jonathan S. Cohen, Kenneth L. Greene, U.S. Dept. of Justice, Washington, D.C., for defendant-appellee.

Before KRAVITCH and CLARK, Circuit Judges, and PECK, Senior Circuit Judge.

JOHN W. PECK, Senior Circuit Judge:

Appellant Rawlin Stovall appeals from the decision of the United States Tax Court determining a deficiency of $1,386,664 and additions to tax of $346,666 and $69,333 in his 1972 tax year. This court has jurisdiction under 26 U.S.C. § 7482. For the reasons set forth below, we affirm.

In 1972, Stovall was the president and principal shareholder of Stovall and Stovall, Inc., a...

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