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TERRELL EQUIPMENT CO. INC. v. C.I.R.

Nos. 02-61019, 02-61043.

343 F.3d 478 (2003)

TERRELL EQUIPMENT COMPANY INC.; Vernon W. Griffin, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Janet M. Griffin, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

August 18, 2003.

Attorney(s) appearing for the Case

William A. Roberts (argued), The Roberts Law Firm, Dallas, TX, for Petitioners-Appellants.

Karen D. Utiger (argued), Tax Div., Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Charles Casazza, Clerk, U.S. Tax Court, Washington, DC, for Respondent-Appellee.

Janet M. Griffin, Edgewood, TX, pro se.

Before WIENER, CLEMENT, and PRADO, Circuit Judges.

WIENER, Circuit Judge:

After a jury acquitted Petitioner-Appellant Vernon Griffin on all charges of criminal tax fraud (evasion), Respondent-Appellee Commissioner of Internal Revenue ("Commissioner") assessed deficiencies, additions to tax, and penalties against all Petitioners-Appellants ("Petitioners" or "taxpayers") for the tax years 1987, 1988, and 1989, the same years involved in the criminal case. The taxpayers challenged that determination in the United States...

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