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CLEVENGER v. C.I.R.

No. 86-3655.

826 F.2d 1379 (1987)

Clifton CLEVENGER, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided August 28, 1987.

Attorney(s) appearing for the Case

Donald William Geerhart, Robert D. Grossman, Jr. (Grossman & Flask, P.C., Washington, D.C., on brief), for petitioner-appellant.

Teresa Ellen McLaughlin, Tax Div., Dept. of Justice (Roger M. Olsen, Asst. Atty. Gen., Michael L. Paup, Gilbert S. Rothenberg, Tax Div., Dept. of Justice, Washington, D.C., on brief), for respondent-appellee.

Before HALL, SPROUSE and WILKINSON, Circuit Judges.

SPROUSE, Circuit Judge:

Clifton L. Clevenger appeals from the decision of the Tax Court denying him relief under the "innocent spouse" provision of the Internal Revenue Code. 26 U.S.C. § 6013(e). The court held him jointly liable with his wife Catherine for personal income tax deficiencies totaling $189,199 for the tax years 1973 through 1977. We affirm.

During the relevant years, Clifton and Catherine Clevenger each owned a fifty-percent interest in...

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