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GENTRY v. U.S.

No. 91-6120.

962 F.2d 555 (1992)

Bernice M. GENTRY; Charles F. Gentry, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided April 24, 1992.

Attorney(s) appearing for the Case

Donald E. Dawson, Ray & Housch, Nashville, Tenn. (argued and briefed), for plaintiffs-appellants.

Josh Eagle, Gary R. Allen, Acting Chief (briefed), William S. Estabrook, Patricia Bowman (argued), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, D.C., Jerry G. Cunningham, U.S. Atty., Office of the U.S. Atty., Chattanooga, Tenn., for U.S.

Before: MERRITT, Chief Judge; MARTIN and SILER, Circuit Judges.

MERRITT, Chief Judge.

The question before us is whether a federal income tax assessment made pursuant to 26 U.S.C. § 6203 and 26 C.F.R. 301.6203-11 is proper and thus permits the Internal Revenue Service to initiate procedures to enforce and collect taxes due. The purposes of the statute and regulations are to insure that a proper record is kept in order to avoid slipshod tax accounting practices...

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