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MUHICH v. COMMISSIONER

Nos. 00-1186 and 00-1187

238 F.3d 860 (2001)

Frank Muhich, Virginia Muhich, and Midwest Portraits Corporation, Petitioners-Appellants, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided January 25, 2001

Attorney(s) appearing for the Case

Joe A. Izen, Jr. (argued), Izen & Associates, Bellaire, TX, for Petitioners-Appellants.

Frank P. Cihlar, Department of Justice, Tax Division, Appellate Section, DC, for Respondent-Appellee in 00-1186.

Frank P. Cihlar, Joel L. McElvain (argued), Department of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee in 00-1187.

Before COFFEY, DIANE P. WOOD, and WILLIAMS, Circuit Judges.

COFFEY, Circuit Judge.

On August 6, 1997, the Commissioner of Internal Revenue issued a notice of deficiency to Frank and Virginia Muhich stating that they had understated their tax liabilities on their joint returns for the 1994 and 1995 tax years. On the same day, the Commissioner also issued a notice of deficiency to Midwest Portraits Corporation (Midwest) for the tax years ending on June 30, 1994, 1995, and 1996.

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