DAVID v. C.I.R.

No. 262, Docket 94-4034.

43 F.3d 788 (1995)

Sheldon Jay DAVID, Marilyn David, Walter David and Marian David, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided January 3, 1995.


Attorney(s) appearing for the Case

Theodore D. Peyser, Washington, DC (Roberts & Holland, Washington, DC, Richard A. Levine, Roberts & Holland, New York City, of counsel), for petitioners-appellants.

Linda E. Mosakowski, Tax Div., Dept. of Justice, Washington, DC (Loretta C. Argrett, Asst. Atty. Gen., Gary R. Allen, Richard Farber, Tax Div., Dept. of Justice, of counsel), for respondent-appellee.

Before: VAN GRAAFEILAND, MINER and McLAUGHLIN, Circuit Judges.


PER CURIAM:

Walter and Marian David, and Sheldon and Marilyn David appeal from decisions of the United States Tax Court (Dawson, J.) imposing negligence penalties under 26 U.S.C. § 6653(a) for underpayment of federal income taxes. We affirm.

Walter and his brother, Sheldon, are experienced and sophisticated businessmen. Walter has a bachelor of business administration degree with a major in accounting; Sheldon has a master of business administration degree...

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