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McINGVALE v. C.I.R.

No. 90-4698 Summary Calendar.

936 F.2d 833 (1991)

George C. and Angela B., McINGVALE, Sr., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

July 30, 1991.

Attorney(s) appearing for the Case

D. Kevin McCorkingdale, Tobolowsky, Prager & Schlinger, Dallas, Tex., for petitioners-appellants.

Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S., Gary R. Allen, Chief, Curtis C. Pett, Kenneth L. Greene, Sara S. Holderness, Appellate Section, Shirley D. Peterson, Asst. Atty. Gen., Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before JOHNSON, SMITH and WIENER, Circuit Judges.

WIENER, Circuit Judge:

This kaleidoscopic federal income tax case was filed in the United States Tax Court by Petitioners-Appellants George C. and Angela B. McIngvale (collectively, Taxpayers) against the Commissioner of Internal Revenue (the Commissioner) for a redetermination of federal income tax deficiencies previously determined by the Internal Revenue Service (IRS). Following a trial on the merits, the tax court ruled in favor of the Commissioner, holding that...

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