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DEATON v. C.I.R.

Nos. 05-60278, 05-60292.

440 F.3d 223 (2006)

Barbara DEATON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Ronny Deaton, Petitioner-Appellant, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

February 9, 2006.

Attorney(s) appearing for the Case

Lawrence R. Jones, Jr., Townsend & Jones, Dallas, TX, for the Deatons.

Annette Marie Wietecha, Gilbert S. Rothenberg, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Robert R. Di Trolio, U.S. Tax Court, Donald L. Korb, Chief Counsel, IRS, Washington, DC, for CIR.

Before GARWOOD, DeMOSS and BENAVIDES, Circuit Judges.

DeMOSS, Circuit Judge:

Barbara and Ronny Deaton (the "Deatons") appeal a decision of the United States Tax Court (the "Tax Court") sustaining a finding of the Internal Revenue Service Appeals Office (the "Appeals Office") that the Deatons' 1994 remittance of $125,000—which accompanied their Form 4868 application for an extension of time to file their 1993 tax return—was a "payment," not a "deposit," and that as such, it could not be credited against...

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