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BOLDING v. C.I.R.

No. 96-60112.

117 F.3d 270 (1997)

Dennis E. BOLDING; Dixie R. Bolding, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

July 18, 1997.

Attorney(s) appearing for the Case

Farley P. Katz, Charles J. Muller, III, Anthony E. Rebollo, III, Wells, Pinckney & McHugh, San Antonio, TX, for Petitioners-Appellants.

Gary R. Allen, Sara Smith Holderness, Loretta Argrett, Asst. Atty. Gen., Richard Bradshaw Farber, U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Charles Casazza, Clerk, U.S. Tax Court, Washington, DC, Stuart L. Brown, Chief Counsel, Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before REAVLEY, GARWOOD and BENAVIDES, Circuit Judges.

GARWOOD, Circuit Judge:

This appeal involves disputed deficiencies in the income tax returns of appellants Dennis and Dixie Bolding, husband and wife, for the taxable years 1988, 1989, and 1990. The Boldings filed a petition contesting the deficiencies in the United States Tax Court. The court entered a memorandum opinion, unofficially reported at 70 T.C. (CCH) 110, rendering a decision in favor of the Commissioner of Internal...

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