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CASSIDY v. C.I.R.

No. 86-2302.

814 F.2d 477 (1987)

Thomas V. CASSIDY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided March 18, 1987.

Attorney(s) appearing for the Case

Martha Brisette, Asst. Atty. Gen., Tax. Div. Dept. of Justice, Washington, D.C., for respondent-appellee.

John E. Cassidy, Cassidy & Mueller, Peoria, Ill., for petitioner-appellant.

Before CUDAHY, and RIPPLE, Circuit Judges, and WILL, Senior District Judge.

RIPPLE, Circuit Judge.

In this case, appellant-taxpayer Thomas V. Cassidy, appeals from the order and decision of the United States Tax Court granting summary judgment for the Commissioner with respect to income tax deficiencies and fraud penalties. For the reasons set forth in this opinion, we affirm the judgment of the tax court.

I

Facts

On June 24, 1980, the Commissioner of Internal Revenue sent the appellant a notice of deficiency in...

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