Frank C. PASTERNAK; Judith Pasternak (92-1681/1682); Anthony J. Cutaia; Diane Cutaia; David G. Koehlinger (92-1681), Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Sixth Circuit.https://leagle.com/images/logo.png
Argued March 15, 1993.
Decided April 8, 1993.
Rehearing Denied June 7, 1993.
Attorney(s) appearing for the Case
Frederick A. Patmon, Detroit, MI, Clarence B. Tucker, Sr. (argued and briefed), Detroit, MI, for petitioners-appellants.
Thomas J. Clark, Trial Attorney (argued), U.S. Dept. of Justice, Tax Div., Gary R. Allen, Acting Chief (briefed), Gilbert S. Rothenberg, U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, DC, for respondent-appellee in No. 92-1681.
Thomas J. Clark, Trial Attorney (argued), U.S. Dept. of Justice, Tax Div., Abraham N.M. Shashy, Jr., Chief Counsel, I.R.S. Office of Chief Counsel, Gary R. Allen, Acting Chief (briefed), Gilbert S. Rothenberg, U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, DC, for respondent-appellee in No. 92-1682.
Before: NELSON, Circuit Judge; and PECK and CONTIE, Senior Circuit Judges.
United States Court of Appeals, Sixth Circuit.
CONTIE, Senior Circuit Judge.
Petitioners-appellants, Frank C. Pasternak and Judith Pasternak; Anthony J. and Diane Cutaia; and David G. Koehlinger, appeal a Tax Court decision upholding tax deficiencies and penalties against them for the taxable years 1981 and 1982 issued by the Commissioner of Internal Revenue, respondent-appellee.
I.
Petitioners are persons who invested in various master recording leasing...
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