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TWEEDDALE v. C.I.R.

Nos. 87-4541, 87-4956 Summary Calendar.

841 F.2d 643 (1988)

Thomas A. TWEEDDALE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

April 7, 1988.

Attorney(s) appearing for the Case

G. Thomas Rhodus, Ronald A. Stein, Brice & Mankoff, Dallas, Tex., for petitioner-appellant.

Michael L. Paup, Chief Appellate Sec., Dept. of Justice, Tax Div., Gary R. Allen, William S. Rose, Jr., Asst. U.S. Attys., Jean Owens, Acting Chief Counsel, IRS, Washington, D.C., for respondent-appellee.

Gary R. Allen, William S. Rose, Jr., William S. Estabrook, Kenneth Rosenberg, Asst. Attys. Gen., William F. Nelson, Chief Counsel, IRS, Michael L. Paup, Chief, Dept. of Justice, Tax Div., Glenn A. Archer, Atty. Gen., Washington, D.C., for respondent-appellee.

Before CLARK, Chief Judge, WILLIAMS and DAVIS, Circuit Judges.

CLARK, Chief Judge:

Thomas A. Tweeddale appeals a United States Tax Court's determination of deficiency on grounds that the Tax Court violated his Fifth Amendment rights. Finding that the Tax Court entered judgment against Tweeddale because he didn't meet his burden of proof in an action he instituted and not because he exercised his privilege against self-incrimination, we affirm.

I.

Thomas A. Tweeddale claimed exemption from income taxes from 1978...

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