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CHILINGIRIAN v. C.I.R.

No. 89-2313.

918 F.2d 1251 (1990)

Jack C. CHILINGIRIAN; Joann E. Chilingirian, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided November 14, 1990.

Attorney(s) appearing for the Case

Francis G. Seyferth, Haddrill & Seyferth, Troy, Mich., for petitioners-appellants.

Peter K. Scott, I.R.S., Gary R. Allen, Acting Chief, Kimberly S. Stanley, Gilbert S. Rothenberg, U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for respondent-appellee.

Before MARTIN and WELLFORD, Circuit Judges, and SILER, Chief District Judge.

BOYCE F. MARTIN, Jr., Circuit Judge.

Jack and Joann Chilingirian appeal the tax court's decision of August 14, 1989, based on its opinion reported at T.C. Memo. 1986-463, 52 T.C.M. (CCH) 606 (Sept. 22, 1986), holding them liable for deficiencies in their federal income taxes for tax years 1978, 1979 and 1980. We affirm.

The only real issue on appeal is how to treat unrealized gain from...

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