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EMMONS v. COMMISSIONER OF INTERNAL REVENUE

No. 89-4414.

898 F.2d 50 (1990)

Gary M. EMMONS and Martha C. Emmons, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Fifth Circuit.

April 11, 1990.

Attorney(s) appearing for the Case

William C. Waller, Jr., Waller, Mark & Allen, Denver, Colo., for petitioners.

Gary R. Allen, Chief, Appellate Section, David M. Moore, Steven W. Parks, Richard Farber, Kimberly S. Stanley, William S. Rose, Jr., Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, William Nelson, Chief Counsel, IRS, Washington, D.C., for respondent.

Before GEE, GARZA and DAVIS, Circuit Judges.

W. EUGENE DAVIS, Circuit Judge:

Gary M. Emmons and Martha C. Emmons (the taxpayers) appeal the tax court's order sustaining the Commissioner of Internal Revenue's (the Commissioner's) determination of tax deficiencies. We affirm.

I.

The taxpayers sought review in the tax court for deficiencies the Commissioner assessed against them for their 1981 and 1982 returns. The Tax Court sustained the Commissioner's determination of deficiencies.

The...

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