MacNAUGHTON v. U.S.

No. 88-5359.

888 F.2d 418 (1989)

David V. MACNAUGHTON and Virginia R. MacNaughton, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided October 23, 1989.

Rehearing and Rehearing Denied December 29, 1989.


Attorney(s) appearing for the Case

John P. Konvalinka, M. Elizabeth McCroskey (Argued), Grant, Konvalinka & Grubbs, Chattanooga, Tenn., for David V. MacNaughton, M.D. and Virginia R. MacNaughton.

John W. Gill, Jr., U.S. Atty., William Sonnenberg, Asst. U.S. Atty., Chattanooga, Tenn., Gary R. Allen, Acting Chief, U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., William S. Rose, Jr., Asst. Atty. Gen., U.S. Dept. of Justice, Tax Div. Appellate Section, J.I. Oppenheimer (argued), Paul M. Predmore, Trial Atty., Office of the U.S. Dept. of Justice, Tax Div., Washington, D.C., for U.S.

Before KENNEDY and JONES, Circuit Judges, and SILER, Chief District Judge.


Rehearing and Rehearing En Banc Denied December 29, 1989.

NATHANIEL R. JONES, Circuit Judge.

Plaintiffs-appellants, David and Virginia MacNaughton, appeal the jury verdict and the district court's denial of their motion for judgment notwithstanding the verdict (JNOV) or a new trial in this action for the recovery of income tax and interest. For the reasons set forth below, we affirm.

I.

Many of the relevant facts in this case are not in dispute...

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