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GOLD EMPORIUM, INC. v. C.I.R.

No. 89-2451.

910 F.2d 1374 (1990)

GOLD EMPORIUM, INC., Michael J. Malicki and Kathleen Malicki, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 14, 1990.

Rehearing Denied November 5, 1990.

Attorney(s) appearing for the Case

Richard J. Sankovitz, Whyte & Hirschboeck, Robert E. Dallman, Mulcahy & Wherry, Milwaukee, Wis., for petitioners-appellants.

Richard Farber, Gary R. Allen, David M. Moore, Janet Bradley, Dept. of Justice, Tax Div., Appellate Section, Charles S. Casazza, U.S. Tax Court, Peter K. Scott, I.R.S., Washington, D.C., for respondent-appellee.

Before BAUER, Chief Judge, FLAUM and RIPPLE, Circuit Judges.

BAUER, Chief Judge.

Petitioners Gold Emporium, Inc. ("Gold Emporium"), Michael J. Malicki ("taxpayer" or "Malicki") and Kathleen Malicki (referred to together with Michael Malicki as "the Malickis") appeal the United States Tax Court's decision upholding, in part, the Commissioner of Internal Revenue's ("Commissioner") tax deficiency assessment against them for unreported income during the tax years 1980 and 1981. Petitioners seek review only of the Tax Court's finding...

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