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SARGENT v. C.I.R.

No. 90-1782.

929 F.2d 1252 (1991)

Gary A. SARGENT and Janice B. Sargent, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Steven M. CHRISTOFF and Tami Jo Christoff, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Steven M. CHRISTOFF, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided April 2, 1991.

Attorney(s) appearing for the Case

John W. Hughes, New York City, for appellants.

Bruce R. Ellisen, Washington, D.C., for appellee.

Before ARNOLD and BEAM, Circuit Judges, and BOGUE, Senior District Judge.

BOGUE, Senior District Judge.

This case, on appeal from the United States Tax Court, is one of first impression for this Court. Initially, the Commissioner of Internal Revenue issued Notices of Deficiency with respect to the federal income taxes of Gary A. Sargent1 for the years 1978 through 1981; and for Steven M. Christoff2 for the years 1980 through 1982.

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