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CONTI v. C.I.R.

No. 93-1281.

39 F.3d 658 (1994)

Guilio J. CONTI and Edith Conti, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided November 9, 1994.

Attorney(s) appearing for the Case

Paul T. Mengel (briefed), Robert B. Pierce (briefed), Mark C. Pierce (argued and briefed), Pierce & Pierce, Birmingham, MI, for appellants.

Gary A. Allen, Acting Chief (briefed), Kenneth L. Greene, David A. Shuster (argued), U.S. Dept. of Justice, Appellate Section, Tax Div., Washington, DC, for appellee.

Before: MARTIN, RYAN, and SUHRHEINRICH, Circuit Judges.

BOYCE F. MARTIN, Jr., Circuit Judge.

Guilio J. Conti and his wife Edith appeal the Tax Court's 99 T.C. 20, 1992 WL 238783; T.C. Memo. 1992-616, 1992 WL 294942 (1992) finding that they substantially understated their income for 1986 and 1987. The Contis also challenge the penalties imposed for fraud and understatement of their tax liability. We affirm.

The record in this case is extensive and confusing, and we summarize...

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