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HENSON v. C.I.R.

No. 87-8091.

835 F.2d 850 (1988)

Kenneth M. HENSON and Sue B. Henson, Petitioners-Appellants, Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Cross-Appellant.

United States Court of Appeals, Eleventh Circuit.

January 15, 1988.

Attorney(s) appearing for the Case

Frank C. Jones, Michael E. Ross, Camille S. Wright, Atlanta, Ga., for petitioners-appellants, cross-appellees.

Roger M. Olsen, Asst. Atty. Gen., Tax Div., Dept. of Justice, Michael L. Paup, Ann Belanger Durney, Michael J. Roach, Washington, D.C., for respondent-appellee, cross-appellant.

Before HILL and FAY, Circuit Judges, and ALLGOOD, Senior District Judge.

FAY, Circuit Judge:

In 1986, the United States Tax Court found taxpayer Kenneth Henson guilty of tax fraud for the 1974 tax year, and assessed a liability of $162,412.20. Henson paid this amount and then appealed the Tax Court's finding to this court pursuant to I.R.C. § 7482(a) (1982) (giving the United States Courts of Appeals jurisdiction to review decisions of the Tax Court).1 The Commissioner of Internal Revenue subsequently...

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