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WESTBROOK v. C.I.R.

No. 94-40652.

68 F.3d 868 (1995)

Billie R. WESTBROOK and Madeline M. Westbrook, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

October 30, 1995.

Attorney(s) appearing for the Case

Robert I. White, Shelley Cashion, Chamberlain, Hrdlicka, White, Williams & Martin, Houston, TX, for appellants.

Andrea R. Tebbets, Richard Farber, Washington, DC, Gary R. Allen, Chief, Appellate Section, Tax Division, Dept. of Justice, Washington, DC, David L. Jordan, Acting Chief of Counsel, IRS, Washington, DC, for appellee.

Before KING and JONES, Circuit Judges, and KAZEN, District Judge.

PER CURIAM:

Billie R. Westbrook and Madeline M. Westbrook appeal the United States Tax Court's affirmance of the Commissioner's determination of deficiencies and additions to tax for negligence and for substantial understatement of tax liability for the tax years 1984-1987. Finding no error, we affirm.

I. FACTUAL AND PROCEDURAL BACKGROUND

Billie R. Westbrook ("Dr. Westbrook") has been a veterinarian since 1955. He and Madeline M. Westbrook ("Mrs...

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