ESTATE OF Thomas P. QUIRK, Deceased, Gregory J. Quirk, Norman D. Rollins, Co-Administrators, Mary C. Quirk, Petitioners-Appellants (90-1129),
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
John P. LAWLER, Eileen F. Lawler, Michael J. Skelly, Georgette T. Skelly, Karim A. Abood, Donna H. Abood, Felix E. Matusky, Florence P. Matusky, Petitioners-Appellees,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant, (90-1183/1185/1186/1187).
United States Court of Appeals, Sixth Circuit.https://leagle.com/images/logo.png
Argued February 4, 1991.
Decided March 25, 1991.
Attorney(s) appearing for the Case
Michel G. Kaplan (argued), J. Lee Woodruff, Steven K. Wood, Boult, Cummings, Conners & Berry, Nashville, Tenn., for Estate of Thomas P. Quirk, Gregory Quirk, and Norman D. Rollins, Co-Administrators.
Joe Vaulx Crockett, III (argued), Nashville, Tenn., for Mary C. Quirk.
Peter K. Scott, I.R.S., Office of Chief Counsel, Washington, D.C., Gary R. Allen, Acting Chief, Robert S. Pomerance (argued), Regina S. Moriarty, Shirley D. Peterson, U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for C.I.R.
Eugene Chester (argued), William H. Whitledge, James H. Kenworthy, Everett, Johnson & Breckinridge, New York City, for John P. and Eileen F. Lawler.
Marcia P. Kaplan, Howrey & Simon, Washington, D.C., Eugene Chester (argued), William H. Whitledge, James H. Kenworthy, Everett, Johnson & Breckinridge, New York City, for Michael J. and Georgette T. Skelly.
Eugene Chester (argued), William H. Whitledge, James H. Kenworthy, Everett, Johnson & Breckinridge, New York City, for Karim A. Abood and Donna H. Abood, and Felix E. Matusky and Florence P. Matusky.
Before JONES and NELSON, Circuit Judges, and JOINER, Senior District Judge.
United States Court of Appeals, Sixth Circuit.
NATHANIEL R. JONES, Circuit Judge.
In this consolidated appeal, petitioners-appellants Estate of Thomas P. Quirk and Mary Quirk appeal the tax court's finding of a tax deficiency for the tax years 1974 and 1975. The Commissioner has filed protective appeals against the tax court's finding of an overpayment to petitioners-appellees John P. Lawler, Felix E. Matusky, Michael J. Skelly and Karim A. Abood.
I.
The dispute in this case centers on the tax...
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