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STENDIG v. U.S.

No. 87-3109.

843 F.2d 163 (1988)

Joseph L. STENDIG; Eileen M. Stendig, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided April 5, 1988.

Attorney(s) appearing for the Case

John Yates Merrell (John Yates Merrell, Jr., John C. Donovan, Merrell & Merrell, P.C., on brief), for plaintiffs-appellants.

Kenneth L. Greene, Tax Div., Dept. of Justice (Michael C. Durney, Acting Asst. Atty. Gen., Michael L. Paup, Jonathan S. Cohen, Tax Div., Dept. of Justice, on brief), for defendant-appellee.

Before WIDENER, MURNAGHAN, and SPROUSE, Circuit Judges.

SPROUSE, Circuit Judge:

Joseph L. Stendig and Eileen M. Stendig appeal the district court's judgment in favor of the Internal Revenue Service (IRS) in their action for a refund of taxes paid on income deposited into accounts to secure the maintenance and operation of an apartment complex they built. The district court held that the funds deposited constituted accrued taxable income for the years 1979, 1980, and 1981. We affirm.

I.

The Stendigs are...

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