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SERIANNI v. C.I.R.

No. 84-5093.

765 F.2d 1051 (1985)

Charles SERIANNI, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant. Josephine M. SERIANNI, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

July 16, 1985.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Michael L. Paup, Chief, Appellate Section, Tax Div., Ann Belanger Durney, Douglas G. Coulter, Washington, D.C., for I.R.S.

Walton, Lantaff, Schroeder & Carson, Charles P. Sacher, Coral Gables, Fla., for Josephine Serianni.

Hugh G. Isley, Jr., Louis J. DeRuil, Jack R. Loving, Ft. Lauderdale, Fla., Patricia A. Willing, Tax Div., Dept. of Justice, Washington, D.C., for Charles Serianni.

Before HILL, KRAVITCH and SMITH, Circuit Judges.

EDWARD S. SMITH, Circuit Judge:

Petitioner-appellant Josephine M. Serianni (Josephine) appeals from a United States Tax Court decision of deficiency in her federal income tax due for 1975, based primarily on that court's holding that she, and not her former husband, Charles Serianni (Charles), is liable for tax imposed on gain realized on the liquidation proceeds of certain corporate stock transferred to Josephine by Charles. We affirm.

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