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SCHUMANN v. C.I.R.

No. 87-1399.

857 F.2d 808 (1988)

Warren H. SCHUMANN and Maria T. Schumann, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided September 23, 1988.

Attorney(s) appearing for the Case

Julian N. Stern, was on the brief, for appellants.

David I. Pincus, Atty., Dept. of Justice, with whom William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen and Richard Farber, Attys. Dept. of Justice, Washington, D.C., were on the brief, for appellee. Michael L. Paup and Michael C. Durney, Attys., Dept. of Justice, Washington, D.C., also entered appearances for appellee.

Before RUTH BADER GINSBURG, D.H. GINSBURG, Circuit Judges, and MacKINNON, Senior Circuit Judge,

Opinion for the Court filed by Senior Circuit Judge MacKINNON.

MacKINNON, Senior Circuit Judge:

Appellants, Warren and Maria Schumann, appeal a decision of the United States Tax Court upholding the Internal Revenue Commissioner's assessment against them of a $7,943.54 deficiency in their 1977 tax payments.1 The narrow issue posed by this case is whether a partial liquidation distribution paid to a taxpayer on stock option shares...

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