SACKS v. C.I.R.

No. 94-70756.

82 F.3d 918 (1996)

Zachary H. SACKS and Salley Sacks, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 6, 1996.


Attorney(s) appearing for the Case

Michael C. Cohen, De Castro, West, Chodorow, and Burns, Los Angeles, California, for the petitioners-appellants.

Gary R. Allen, Tax Division, United States Department of Justice, Washington, D.C., for the respondent-appellee.

Before: GOODWIN and HAWKINS, Circuit Judges, and JAMES WARE, District Judge.


GOODWIN, Circuit Judge:

Zachary and Salley Sacks appeal an order imposing penalties for the negligent under-payment of taxes. 26 U.S.C. §§ 6653(a) and 6661(a). We affirm the judgment of the Tax Court.

I.

The facts of this case are set out in detail in the Tax Court's opinion. We summarize the most pertinent ones here.

The Sacks claimed investment losses and deductions for 1981 and 1982 from their participation in Far West Drilling...

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