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ADDINGTON v. C.I.R.

Docket Nos. 98-4145(L), 98-4146(CON), 98-4147(CON), 99-4183(CON), 99-4187(CON), 99-4185(CON).

205 F.3d 54 (2000)

Laurence M. ADDINGTON, David M. Cohn, John Sann and Marianne Sann, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided: February 29, 2000.

Attorney(s) appearing for the Case

Stuart A. Smith, Law Office of Stuart A. Smith, Esq., New York, NY, for petitioners-appellants.

Joan I. Oppenheimer, U.S. Department of Justice, Tax Division, Washington, D.C. (Loretta C. Argrett, Assistant Attorney General; Ann B. Durney, on the brief), for respondent-appellee.

Before: WINTER, Chief Judge, NEWMAN, and SOTOMAYOR, Circuit Judges.

SOTOMAYOR, Circuit Judge:

Petitioners-appellants Laurence M. Addington, David M. Cohn, and John and Marianne Sann (collectively the "Taxpayers") appeal from the June 10, 1997 decision of the United States Tax Court (Howard A. Dawson, Jr., Judge, adopting the opinion of Special Trial Judge Norman H. Wolfe) upholding respondent-appellee the Commissioner of Internal Revenue's assessment of deficiencies, negligence penalties under I.R.C. § 6653(a)(1)-(2), and valuation...

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