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JONES v. C.I.R.

Nos. 88-2948, 88-2811.

903 F.2d 1301 (1990)

Cornell M. JONES, Petitioner-Appellant, Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee, Cross-Appellant.

United States Court of Appeals, Tenth Circuit.

May 21, 1990.

Attorney(s) appearing for the Case

Mark J. Rochon (W. Gary Kohlman, on the briefs), Kohlman & Fitch, Washington, D.C., for petitioner-appellant, cross-appellee.

Charles E. Brookhart (James I.K. Knapp, Acting Asst. Atty. Gen., Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and Laura Marie Conley O'Hanlon, with him on the briefs), Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee, cross-appellant.

Before McKAY, ANDERSON and BALDOCK, Circuit Judges.

STEPHEN H. ANDERSON, Circuit Judge.

Cornell Jones appeals a decision of the United States Tax Court sustaining an income tax deficiency for the calendar year 1985 in the amount of $16,490,402 together with additions to tax under 26 U.S.C. §§ 6651(a)(1), 6653(a)(1), 6654, and 6661 totalling $4,125,107. Jones v. Commissioner, No. 36601-86 (T.C. Aug. 18, 1988) (Decision); R. Vol. I, Tab 27.1 The Tax Court made no mention...

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