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STONE v. C.I.R.

No. 87-1589, et al.

865 F.2d 342 (1989)

Andrew L. STONE, et al., Appellants, v. COMMISSIONER OF THE INTERNAL REVENUE SERVICE.

United States Court of Appeals, District of Columbia Circuit.

Decided January 10, 1989.

Attorney(s) appearing for the Case

Michael L. Saltzman, for Andrew L. Stone, John S. Nolan, for M. Jeanne Stone, Edward F. Canfield, Washington, D.C., for Francis N. Rosenbaum, appellants.

Elaine F. Ferris, Atty., Dept. of Justice, with whom William S. Rose, Jr., Asst. Atty. Gen., and Gary R. Allen, Atty., Dept. of Justice, were on the brief, for appellee.

Michael L. Paup, Washington, D.C., also entered an appearance for C.I.R.

Before EDWARDS and WILLIAMS, Circuit Judges, and REYNOLDS, Senior District Judge for the Eastern District of Wisconsin.

Opinion for the Court filed by Circuit Judge WILLIAMS.

STEPHEN F. WILLIAMS, Circuit Judge:

Andrew L. Stone and Francis N. Rosenbaum appeal from judgments of the Tax Court finding several million dollars of tax and penalties due on income allegedly received in 1963-67. (Stone's wife, M. Jeanne Stone, also appeals from a judgment imposing liability on her as recipient of an allegedly fraudulent transfer from Stone, but under our disposition her contentions are...

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