ERICKSON v. C.I.R.

No. 90-9008.

937 F.2d 1548 (1991)

Sidney A. ERICKSON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

July 9, 1991.


Attorney(s) appearing for the Case

Mark H. Scheffel (John D. Moats with him on the briefs), John D. Moats & Associates, P.C., Denver, Colo., for petitioner-appellant.

Joy Pritts (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and Charles E. Brookhart, Attys., with her on the brief), Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before ANDERSON and McWILLIAMS, Circuit Judges, and ALLEY, District Judge.


STEPHEN H. ANDERSON, Circuit Judge.

Sidney A. Erickson appeals from a decision of the United States Tax Court sustaining an income tax deficiency for the taxable year 1983 in the amount of $135,379 plus additions to tax under 26 U.S.C. §§ 6651(a)(1), 6653(a)(1) and 6654, totalling $23,412. R. at Tab 19; see Erickson v. Commissioner, 58 T.C.M. 352 (CCH) (Memo. 1989-552 filed Oct. 10, 1989). We affirm.

On May 9, 1983, Erickson flew a Cessna...

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