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KORSHIN v. C.I.R.

No. 95-1930.

91 F.3d 670 (1996)

Jonathan D. KORSHIN, Petitioner-Appellant, v. COMMISSIONER OF the INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided August 7, 1996.

Attorney(s) appearing for the Case

ARGUED: Benjamin Pratt Gasque, Jr., Myrtle Beach, South Carolina, for Appellant. Sarah Kay Knutson, Tax Division, United States Department of Justice, Washington, DC, for Appellee. ON BRIEF: Loretta C. Argrett, Assistant Attorney General, Gary R. Allen, Charles E. Brookhart, Tax Division, United States Department of Justice, Washington, DC, for Appellee.

Before NIEMEYER and WILLIAMS, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

Affirmed by published opinion. Senior Judge PHILLIPS wrote the opinion, in which Judge NIEMEYER and Judge WILLIAMS joined.

OPINION

PHILLIPS, Senior Circuit Judge:

In 1993, the IRS assessed a deficiency against Jonathan Korshin, requiring him to pay an addition-to-tax due to his negligent underpayment of income taxes for the years 1983 to 1988. Korshin petitioned the Tax Court, claiming that the IRS could not now assess this deficiency against him...

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