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DIAMOND v. C.I.R.

No. 89-2817.

930 F.2d 372 (1991)

Louis H. DIAMOND, Madelene Diamond, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided April 11, 1991.

As Amended May 6, 1991.

Attorney(s) appearing for the Case

Gerald William Heller, argued (Samuel P. Kastner, Robin K. Gold, on brief), Laxalt, Washington, Perito & Dubuc, Washington D.C., for petitioners-appellants.

Robert Leslie Baker, argued (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, Robert S. Pomerance, Peter K. Scott, Acting Chief Counsel, I.R.S., on brief), Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before PHILLIPS, Circuit Judge, SMITH, Senior United States Circuit Judge for the Federal Circuit sitting by designation, and YOUNG, Senior U.S. District Judge for the District of Maryland, sitting by designation.

EDWARD S. SMITH, Senior Circuit Judge:

Louis H. Diamond and Madelene Diamond appeal the decision of the United States Tax Court, entered July 20, 1989, pursuant to its opinion filed February 23, 1989. The Tax Court found taxpayers liable for deficiencies in income tax for the tax years 1981 and 1982 in the respective amounts $20,943.09 and $7,922.00, with interest.1

Taxpayers2 appeal only one issue...

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