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DILLON v. C.I.R.

No. 89-4581.

902 F.2d 406 (1990)

Sammy R. and Pamela Kay DILLON, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

June 5, 1990.

Attorney(s) appearing for the Case

Sam Dillon, Timpson, Tex., pro se,

Gary R. Allen, Debroah Swann, Ann B. Durney, Chief Appellate Sec., William Rose, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Peter K. Scott, Acting Chief Counsel, IRS, Washington D.C., for C.I.R.

Before GOLDBERG, REAVLEY, and HIGGINBOTHAM, Circuit Judges.

GOLDBERG, Circuit Judge:

Statement of Facts

In 1982 and 1983, Sam Dillon contracted with the Houston Chronicle (the Chronicle) to deliver newspapers to residences and businesses and to stock vending machines on two routes. Pamela Dillon, his wife, delivered the newspapers on one route while Mr. Dillon delivered them on the other. Ms. Dillon did not contract with the Chronicle.

The Chronicle required Mr. Dillon to use and insure vehicles meeting...

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