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CAULFIELD v. C.I.R.

Nos. 93-4054 and 93-4057.

33 F.3d 991 (1994)

Joseph P. CAULFIELD, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided August 29, 1994.

Rehearing and Suggestion for Rehearing Denied October 19, 1994.

Attorney(s) appearing for the Case

Jerry L. Suddarth, O'Fallon, MO, argued, for appellant.

William J. Patton, Washington, DC, argued (Loretta C. Argrett and Richard Farber, on the brief), for appellee.

Before BEAM, Circuit Judge, HENLEY, Senior Circuit Judge, and LOKEN, Circuit Judge.

Rehearing and Suggestion for Rehearing En Banc Denied October 19, 1994.

LOKEN, Circuit Judge.

Using the bank-deposits-plus-cash-expenditures method to reconstruct taxable income, the Commissioner of Internal Revenue determined that Joseph Caulfield, a public insurance adjuster, underpaid his 1982 and 1984 federal income taxes. The Commissioner assessed tax deficiencies for those years, including negligence and underpayment additions. The Tax Court upheld the...

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