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UNITED STATES v. JENKINS

No. 85-1114. Summary Calendar.

780 F.2d 518 (1986)

UNITED STATES of America, Plaintiff-Appellee, v. Leroy J. JENKINS, and Ann Jenkins, Defendants-Appellants.

United States Court of Appeals, Fifth Circuit.

January 15, 1986.

Attorney(s) appearing for the Case

Leroy J. Jenkins, Ann Jenkins, pro se.

James A. Rolfe, U.S. Atty., Fort Worth, Tex., Victor Conrad, Tax Div., Dept. of Justice, Dallas, Tex., Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., Michael L. Paup, Chief, Appellate Sec., William S. Estabrook, Joan I. Oppeheimer, Attys., Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Before CLARK, Chief Judge, and WILLIAMS and HIGGINBOTHAM, Circuit Judges.

PER CURIAM.

I

In August 1976, taxpayers Leroy J. and Ann M. Jenkins were notified of deficiencies for the tax years 1972 through 1974. On November 26, 1976, a letter was filed in the United States Tax Court. The letter, which was captioned "PETITION," stated: "I hereby PROTEST your Notice of Deciciency [sic] dated Aug. 24, 1976 Ident. No: DD:Dallas:A:S:90-D:306." Beneath this sentence were Leroy Jenkins' signature and the typewritten names of both...

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