BHADA v. C.I.R.

No. 88-2118.

892 F.2d 39 (1989)

Rohinton K. BHADA, Patricia A. Bhada, Petitioners-Appellees, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided December 19, 1989.


Attorney(s) appearing for the Case

John P. Carroll, Jr., argued, Leslie J. Hoffman, James D. Liss, Richard M. Fabbro, Davis, Polk & Wardell, New York City, for petitioners-appellees.

William F. Nelson, I.R.S., Gary R. Allen, Acting Chief, William S. Rose, Ernest J. Brown, argued, U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for respondent-appellant.

Before: KEITH and WELLFORD, Circuit Judges; and GILMORE, District Judge.


WELLFORD, Circuit Judge.

We shall refer to appellees collectively as "Bhada" in this appeal from a decision of the Tax Court reported at 89 T.C. 959 (1987). The opinion of Judge Nims of the Tax Court set out the following stipulated facts in this case:

Petitioners Rohinton and Patricia Bhada were residents of Alliance, Ohio, and petitioners Edward and Janice Caamano were residents of New Orleans, Louisiana, when the petitions...

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