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ZINNIEL v. C.I.R.

No. 88-1531.

883 F.2d 1350 (1989)

John C. ZINNIEL and Gayle A. Zinniel, David N. Merryfield and Jane A. Merryfield, James G. Samuels and Margaret Samuels, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided September 6, 1989.

Rehearing and Rehearing Denied October 18, 1989.

Attorney(s) appearing for the Case

Eugene O. Duffy, Linda E. Mosakowski, Randall L. Nash, O'Neil Cannon & Hollman, Milwaukee, Wis., for petitioners-appellants.

William F. Nelson, I.R.S., Washington, D.C., for C.I.R.

Before CUDAHY and RIPPLE, Circuit Judges, and WILL, Senior District Judge.

Rehearing and Rehearing En Banc Denied October 18, 1989.

RIPPLE, Circuit Judge.

This is an appeal from the Tax Court's denial of the appellants' motion for litigation costs. On June 6, 1984, the Commissioner of Internal Revenue (Commissioner) issued a notice of tax deficiency to the appellants. The appellants filed timely petitions in the Tax Court for the redetermination of the deficiencies. The Tax Court then ruled...

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