HUBBARD v. C.I.R.

No. 88-1390.

872 F.2d 183 (1989)

Charles E. HUBBARD, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided April 12, 1989.


Attorney(s) appearing for the Case

Geoffrey J. O'Conner argued, Garden City, N.Y., for petitioner-appellee.

Gary R. Allen, Acting Chief, U.S. Dept. of Justice, Appellate Section Tax Div., Janet S. Kimball argued, William S. Rose, Jr., Jane S. Kimball, David English Carmack, U.S. Dept. of Justice, Tax Div. Appellate Section, Joseph T. Chalhoub, Washington, D.C., for respondent-appellant.

Before KRUPANSKY and WELLFORD, Circuit Judges, and JOINER, Senior District Judge.


PER CURIAM.

During each of the years 1976, 1977, 1978, and 1979, Charles Hubbard filed federal income tax returns in which he held a partnership interest in a tax shelter. He claimed loss deductions and investment credits with respect to the shelter on each return. After the returns were filed with the Internal Revenue Service (IRS), they were audited by the District Director in Detroit, Michigan.

Section 6501(a) of the I.R.C. generally requires the IRS to...

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