SISK v. C.I.R.

No. 85-1310.

791 F.2d 58 (1986)

James W. SISK, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 22, 1986.


Attorney(s) appearing for the Case

James W. Sisk, Madison, Tenn., for petitioner-appellant.

Michael L. Paup, Tax Division, U.S. Dept. of Justice, Washington, D.C., Carleton D. Powell, Gary D. Gray, Washington, D.C., for respondent-appellee.

Before: KEITH and KENNEDY, Circuit Judges, and UNTHANK, District Judge.


KEITH, Circuit Judge.

This is an appeal from a judgment of the Tax Court which determined that the taxpayer, James W. Sisk, was deficient in the payment of federal income taxes for the years 1979-80 in the amount of $59,674. The Tax Court imposed a fifty percent civil fraud penalty of $29,837 against the taxpayer pursuant to 26 U.S.C. § 6653(b). The Tax Court also found taxpayer liable under 26 U.S.C. § 6654 in the amount of $3,158 due to underpayment of...

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