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YOON v. C.I.R.

No. 97-60252.

135 F.3d 1007 (1998)

Hee S. YOON; Jung K. Yoon, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 6, 1998.

Attorney(s) appearing for the Case

John Edward Leeper, El Paso, TX, for Petitioners-Appellants.

Sara Ann Ketchum, Loretta Argrett, Asst. U.S. Atty. Gen., U.S. Dept. of Justice, Tax Div., Appellate Section, Washington, DC, David I. Pincus, Dept. of Justice, Tax Div., Washington, DC, Charles Casazza, Clerk, U.S. Tax Court, Washington, DC, Stuart L. Brown, Chief Counsel, IRS, Washington, DC, for Respondent-Appellee.

Before REYNALDO G. GARZA, DUHÉ and STEWART, Circuit Judges.

REYNALDO G. GARZA, Circuit Judge:

The Internal Revenue Service ("IRS") used the net worth plus personal living expenses method to determine the Yoons' unreported income. The Tax Court modified this determination in part, and sustained it in part. The Yoons claim error in the determination of their nondeductible personal living expenses, and in the Tax Court's refusal to reduce their opening net worth by the amount of certain credit card liabilities. We find that the...

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