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OGDEN v. C.I.R.

No. 85-4476.

788 F.2d 252 (1986)

Mary K.S. OGDEN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied May 27, 1986.

Attorney(s) appearing for the Case

Robert G. Jackson, Baton Rouge, La., petitioner-appellant.

Fred T. Goldberg, Jr., Chief Counsel, IRS, Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Michael L. Paup, Chief, Appellate Sec., David English Carmack, Steven I. Frahm, Roger M. Olsen, Attys., Washington, D.C., for respondent-appellee.

Before REAVLEY, RANDALL and DAVIS, Circuit Judges.

PER CURIAM:

AFFIRMED on the basis of the Tax Court opinion, Ogden v. Commissioner, 84 T.C. 871 (1985), a copy of which is attached hereto.

84 T.C. 57

UNITED STATES TAX COURT

MARY K. S. OGDEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 22866-82 Filed May 16, 1985.

SIMPSON, Judge:

The Commissioner...

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