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DAY v. C.I.R.

No. 91-2991.

975 F.2d 534 (1992)

Stephen S. DAY; Jeanette L. Day, Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee. Richard D. WISE, Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided September 17, 1992.

Attorney(s) appearing for the Case

Daniel W. Schermer, Minneapolis, Minn., argued, for appellants.

Regina S. Moriarty, Washington, D.C., argued (Gary R. Allen, Ann B. Durney and Regina S. Moriarty, on the brief), for appellee.

Before BOWMAN and BEAM, Circuit Judges, and LARSON, District Judge.

BEAM, Circuit Judge.

This appeal arises from a final judgment entered in the United States Tax Court finding that Stephen and Jeanette Day and Richard Wise, under-reported income for the tax years 1982 and 1983, in violation of the Internal Revenue Code. They appeal this deficiency judgment, as well as the Tax Court's assessment of penalties for fraud under Internal Revenue Code section 6653(b) and for substantial understatement...

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