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LAZORE v. C.I.R.

No. 92-7667.

11 F.3d 1180 (1993)

Glenny A. LAZORE, Carol L. Lazore, Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE.

United States Court of Appeals, Third Circuit.

Decided December 6, 1993.

Attorney(s) appearing for the Case

Peter Goldberger (argued), James H. Feldman, Jr., Pamela A. Wilk, Law Office of Peter Goldberger, Philadelphia, PA, for appellants.

Michael L. Paup, Acting Asst. Atty. Gen., Gary R. Allen, Richard Farber, Edward T. Perelmuter, David A. Shuster (argued), U.S. Dept. of Justice, Tax Div., Washington, DC, for appellee.

Before: STAPLETON, ROTH and LEWIS, Circuit Judges.

OPINION OF THE COURT

ROTH, Circuit Judge:

This appeal arises from the United States Tax Court's determination that appellants, Glenny and Carol Lazore, were not exempt from paying federal income taxes and that they were subject to both late filing and negligence penalties on the basis of their unexcused two-week delay in filing their return. On December 23, 1988, the Commissioner of the Internal Revenue Service sent the Lazores a notice of deficiency concerning...

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