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HARRISON v. C.I.R.

No. 87-2350.

854 F.2d 263 (1988)

Thomas C. HARRISON and Rita Harrison, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 15, 1988.

Attorney(s) appearing for the Case

Philip W. Sandler, Chicago, Ill., for petitioners-appellants.

Janet Kay Jones (Michael L. Paup, Chief), Appellate Sec. Tax. Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before WOOD, Jr., CUDAHY, and RIPPLE, Circuit Judges.

HARLINGTON WOOD, Jr., Circuit Judge.

Petitioners-appellants, Thomas C. Harrison and Rita Harrison (the Harrisons), filed a petition in the United States Tax Court in order to contest the purported deficiency set forth in a notice of deficiency issued by respondent-appellee, Internal Revenue Service (IRS), prior to completion of an audit. When the audit was eventually concluded, the IRS conceded that there was no deficiency due from the Harrisons. The Harrisons then...

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