SENDA v. C.I.R.

No. 05-1118.

433 F.3d 1044 (2006)

Mark W. SENDA and Michele Senda, Appellants, v. COMMISSIONER OF INTERNAL REVENUE Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: January 6, 2006.


Attorney(s) appearing for the Case

Daniel V. Conlisk, argued, St. Louis, MO (James R. Dankenbring and James R. Loranger, on the brief), for petitioners.

Bethany B. Hauser, argued, U.S. Dept. of Justice, Tax Division, Washington, DC (Jonathan S. Cohen, U.S. Dept. of Justice, Tax Div., on the brief), for respondent.

Before MELLOY, BEAM, and BENTON, Circuit Judges.


BENTON, Circuit Judge.

Mark W. Senda and his wife, Michele Senda, received a notice from the Commissioner of Internal Revenue for deficiencies in gift tax. Reviewing their petition, the tax court1 found deficiencies of $185,572 for 1998 and $276,321 for 1999. See Senda v. Comm'r, 2004 WL 1551275 (T.C. Memo.2004-160) (U.S.Tax Ct.,2004). The Sendas appeal under Section 7482 of the Internal Revenue Code. This court affirms.

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