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McMURRAY v. C.I.R.

Nos. 92-1513, 92-1628.

985 F.2d 36 (1993)

Homer F. and Dorothy L. McMURRAY, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee. Homer F. and Dorothy L. McMURRAY, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

February 9, 1993.

Attorney(s) appearing for the Case

Aline H. Lotter, Manchester, NH, for petitioners, appellants.

Gary R. Allen with whom James A. Bruton, Acting Asst. Atty. Gen., Tax Div., Dept. of Justice, Bruce R. Ellisen, Washington, DC, and William J. Patton, Pittsburgh, PA, and Abraham N.M. Shashy, Jr., Dallas, TX, were on brief, for respondent, appellee.

Before TORRUELLA, Circuit Judge, BOWNES, Senior Circuit Judge, and STAHL, Circuit Judge.

STAHL, Circuit Judge.

In these consolidated appeals, Dorothy L. McMurray and Homer F. McMurray ("the McMurrays"), challenge decisions of the United States Tax Court which upheld determinations made by the Commissioner of Internal Revenue ("the Commissioner") that the McMurrays are jointly liable for income tax deficiencies for 1984 through 1988, as well as penalties stemming from those deficiencies. The deficiencies are based on the Commissioner's conclusion that...

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