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WHITE v. C.I.R.

No. 92-9005.

991 F.2d 657 (1993)

Matthew R. WHITE and Jill White, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

April 20, 1993.

Attorney(s) appearing for the Case

Craig F. McCullough (L.S. McCullough, with him on the brief), of Callister, Duncan & Nebeker, Salt Lake City, UT, for petitioners-appellants.

Annette M. Wietecha, Atty., Tax Div., Dept. of Justice, Washington, DC (James A. Bruton, Acting Asst. Atty. Gen., and Ann B. Durney, Atty., Tax Div., Dept. of Justice, Washington, DC, with her on the brief), for respondent-appellee.

Before KELLY and SETH, Circuit Judges, and ALLEY, District Judge.

SETH, Circuit Judge.

The issue raised on this appeal is whether the Commissioner of the Internal Revenue Service, in his notice of deficiency, correctly assessed taxes against the general partners of a Utah limited partnership. Appellants Matthew R. White and Jill White, general partners of M & J Investment Company, a limited partnership in Utah, appeal the judgment of the United States Tax Court sustaining an assessment by the Commissioner of the Internal Revenue...

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