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KORECKY v. C.I.R.

No. 85-3387.

781 F.2d 1566 (1986)

Clayton M. KORECKY, Jr., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

February 14, 1986.

Attorney(s) appearing for the Case

Stephen G. Salley, Akerman, Senterfitt & Eidson, Orlando, Fla., for petitioner-appellant.

Glenn L. Archer, Jr., Asst. Atty. Gen., Mary Frances Clark, Michael L. Paup, Chief, Appellate Section, Phoebe A. Mix, U.S. Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before HILL, Circuit Judge, TUTTLE and HENDERSON, Senior Circuit Judges.

PER CURIAM:

In this appeal Clayton M. Korecky, Jr. challenges the decision of the United States Tax Court imposing a fifty-percent civil penalty against him for tax fraud. The Tax Court found that Korecky had understated his tax liability for the years 1972, 1973 and 1974 and that this tax deficiency was the result of fraud. On this appeal, Korecky does not challenge the judgment of tax liability. His sole contention is that the Tax Court erred in finding fraud and...

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