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U.S. v. WALTON

No. 89-1706.

909 F.2d 915 (1990)

UNITED STATES of America, Plaintiff-Appellee, v. William L. WALTON, also known as Chris Walton; Belle Isle Riding Academy, Defendants-Appellants.

United States Court of Appeals, Sixth Circuit.

Decided July 31, 1990.

Attorney(s) appearing for the Case

Gary R. Allen, Acting Chief, Charles E. Brookhart, Kenneth W. Rosenberg (argued), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, D.C., for plaintiff-appellee.

Jonathan B. Simon, Donald J. Morbach & Associates, Detroit, Mich., John B. Payne, Jr. (argued), Dearborn, Mich., for defendants-appellants.

Before MARTIN and GUY, Circuit Judges, and DOWD, District Judge.

RALPH B. GUY, Jr., Circuit Judge.

Defendants, William Walton and the Belle Isle Riding Academy, Inc. (BIRA or the Academy), appeal a district court judgment holding them jointly and severally liable for payment of federal income taxes and fraud penalties assessed by the Internal Revenue Service (IRS). The defendants allege three general grounds for reversal of the court's order: (1) that the tax deficiencies calculated by the IRS for both defendants were arbitrary...

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