No. 88-2323.

877 F.2d 1364 (1989)

Stephen B. SCALLEN and Chacke Y. Scallen, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided June 9, 1989.

Attorney(s) appearing for the Case

David R. Brennan, Minneapolis, Minn., for appellants.

Steven W. Parks, Washington, D.C., for appellee.

Before FAGG, Circuit Judge, FLOYD R. GIBSON and TIMBERS, Senior Circuit Judges.

TIMBERS, Circuit Judge.

Stephen B. Scallen (Scallen) and Chacke Y. Scallen (collectively appellants) appeal from a decision (No. 6913-85) entered May 26, 1988 in the United States Tax Court, Mary Ann Cohen, Judge,1 determining deficiencies totaling $555,220 in appellants' federal income tax for the tax years 1976, 1977, 1979 and 1981. The court also imposed on Scallen2 additions to tax of $409,525 as...

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