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SOCHIA v. C.I.R.

Nos. 93-5601, 93-8805 Summary Calendar.

23 F.3d 941 (1994)

Maurice H. SOCHIA and Beatrice M. Sochia, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Maurice H. SOCHIA and Beatrice M. Sochia, Plaintiffs-Appellants, v. UNITED STATES of America, et al., Defendants-Appellees.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied August 3, 1994.

Attorney(s) appearing for the Case

Maurice H. Sochia, Beatrice M. Sochia, pro se.

Gary R. Allen, Chief, Appellate Section, Tax Div., Dept. of Justice, Sally J. Schornstheimer, Richard Farber, Robert L. Baker, David L. Jordan, Acting Chief Counsel, IRS, Washington, DC, for respondent-appellee, in No. 93-8805.

Gary R. Allen, Chief, Appellate Sec., Tax Div., Sally J. Schornstheimer, Dept. of Justice, Richard Farber, Robert L. Baker, Washington, DC, A. Ellouise Niblo, Dept. of Justice, Tax Div., Dallas, TX, for U.S.A., IRS et al.

Before POLITZ, Chief Judge, JOLLY and DUHÉ, Circuit Judges.

POLITZ, Chief Judge:

These two appeals are consolidated for today's disposition. In docket number 93-5601, Maurice H. and Beatrice M. Sochia appeal the decision of the Tax Court dismissing their action and affirming the Commissioner's determination of a tax deficiency and additions thereto. In docket number 93-8805 the Sochias appeal the summary judgment dismissal by the district court of their action seeking a refund of a $500 penalty imposed for filing a frivolous...

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