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UTLEY v. C.I.R.

No. 89-4449.

906 F.2d 1033 (1990)

Walter A. UTLEY and Vermelle S. Utley, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

July 13, 1990.

Attorney(s) appearing for the Case

William H. Lawson, Jr., Arlie C. Hooper, Bogatin, Lawson & Chiapella, Memphis, Tenn., for petitioners-appellants.

Peter K. Scott, Acting Chief Counsel, I.R.S., Kimberly Stanley, Gary R. Allen, Gilbert S. Rothenberg, William S. Rose, Jr., Asst. Atty. Gen., Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before POLITZ, KING and WILLIAMS, Circuit Judges.

PER CURIAM:

Walter A. Utley and Vermelle S. Utley (collectively, Taxpayers) appeal from the decision of the tax court holding them liable for deficiencies in their federal income tax payments for 1979 through 1982. Utley v. Commissioner, 56 T.C.M. (CCH) 885 (1988). We agree with the tax court's conclusion that Taxpayers were liable for deficiencies relating to their installment sale of an office building and acreage to their...

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