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ZUHONE v. C.I.R.

No. 88-2248.

883 F.2d 1317 (1989)

William H. ZUHONE, Jr. and Audra M. Zuhone, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 28, 1989.

Attorney(s) appearing for the Case

H. Kent Heller, Naperville, Ill., for petitioners-appellants.

Gary R. Allen, William S. Rose, Jr., Asst. Atty. Gen., Dept. of Justice, Tax Div., Appellate Section, William F. Nelson, I.R.S., Charles Bricken, David I. Pincus, Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before CUMMINGS, CUDAHY and FLAUM, Circuit Judges.

CUMMINGS, Circuit Judge.

Petitioners William H. Zuhone, Jr. and his wife Audra have appealed from a decision of the Tax Court holding that there was a deficiency in income tax amounting to $467,746.91 for 1975 (App. A15). The Tax Court held that certain overriding royalty interests in oil and gas wells must be included in petitioners' 1975 and 1976 taxable income1 and also accepted the evaluation of those interests supplied by the Commissioner...

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