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BALKISSOON v. C.I.R.

No. 92-2078.

995 F.2d 525 (1993)

Basdeo BALKISSOON; Gloria Balkissoon, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided June 11, 1993.

Attorney(s) appearing for the Case

Brett Weiss, Olney, MD, argued, for petitioners-appellants.

David Alan Shuster, Tax Div., U.S. Dept. of Justice, Washington, DC, argued (James A. Bruton, Acting Asst. Atty. Gen., Gary R. Allen, Gilbert S. Rothenberg, Tax Div., U.S. Dept. of Justice, on brief), for respondent-appellee.

Before ERVIN, Chief Judge, and PHILLIPS and MURNAGHAN, Circuit Judges.

OPINION

ERVIN, Chief Judge:

On May 5, 1986, the Commissioner of Internal Revenue ("Commissioner") mailed by regular post a notice of deficiency to Basdeo and Gloria Balkissoon ("Taxpayers") detailing a $33,268.58 deficiency in Taxpayers' 1981 federal income tax paid. By way of the notice of deficiency, the Commissioner also assessed tax additions due to negligent failure to file pursuant to Internal Revenue Code ("IRC") sections 6651(a)(1), 6653(a)(1), and...

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