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WEBER v. C.I.R.S.

No. 94-2609.

60 F.3d 1104 (1995)

Michael D. WEBER; Barbara L. Weber, Petitioners-Appellants, v. COMMISSIONER OF the INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided July 31, 1995.

Attorney(s) appearing for the Case

ARGUED: Randolph Luther Worth, Raleigh, NC, for appellants. Kenneth L. Greene, Tax Div., U.S. Dept. of Justice, Washington, DC, for appellee. ON BRIEF: Samuel W. Witwer, Jr., Brian M. Waldron, Daniel G. Musca, Witwer, Poltrock & Giampietro, Chicago, IL; Mary K. Logan, David A. Ullrich, Evanston, IL, for appellants. Loretta C. Argrett, Asst. Atty. Gen., Gary R. Allen, John A. Dudeck, Jr., Tax Div., U.S. Dept. of Justice, Washington, DC, for appellee.

Before WIDENER and HALL, Circuit Judges, and SPROUSE, Senior Circuit Judge.

Affirmed by published PER CURIAM opinion. Judge WIDENER wrote a dissenting opinion.

PER CURIAM:

Michael D. and Barbara L. Weber appeal a final order of the Tax Court, which upheld a notice of deficiency issued to them by the Commissioner of Internal Revenue. After considering the briefs and arguments of the parties, we affirm the judgment of the Tax Court for the reasons stated in its memorandum opinion, which we adopt as our own and reproduce in the appendix...

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