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MAUERMAN v. C.I.R.

No. 93-9009.

22 F.3d 1001 (1994)

George S. MAUERMAN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

April 25, 1994.

Attorney(s) appearing for the Case

William E. Farrior of Barrow, Gaddis, Griffith & Grimm, Tulsa, OK, for appellant.

Janet A. Bradley (Michael L. Paup, Acting Asst. Atty. Gen., and Ann B. Durney, Tax Division, Dept. of Justice, with her on the brief), Washington, DC, for appellee.

Before KELLY, Circuit Judge, BARRETT, Senior Circuit Judge, and THEIS, Senior District Judge.

BARRETT, Senior Circuit Judge.

George S. Mauerman (Mauerman/Petitioner) appeals from a tax court decision upholding a penalty for substantial understatement of tax under 26 U.S.C. § 6661(c) for calendar years 1984 and 1986 imposed by the Commissioner of Internal Revenue (Commissioner).

Factual Background

Because Mauerman does not challenge the tax court's Findings of Fact, we fully adopt them. The tax court found in relevant part:

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