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HAURY v. C.I.R.

No. 13-1780.

751 F.3d 867 (2014)

Harry Robert HAURY, Appellant v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: May 12, 2014.

Attorney(s) appearing for the Case

Sanford Jay Boxerman , argued, Saint Louis, MO, for Appellant.

Joan I. Oppenheimer , argued, Washington, DC, for Appellee.

Regina S. Moriarty , on the brief, Washington, DC, for Appellee.

Before LOKEN, MURPHY, and SMITH, Circuit Judges.

LOKEN, Circuit Judge.

Harry Haury, a software engineer, filed no federal individual income tax return for 2007. The Commissioner of Internal Revenue issued a notice of deficiency in May 2010, alleging unpaid taxes, penalties, and interest of more than $250,000 based on a substitute return prepared by the Internal Revenue Service. The deficiency asserted taxable salary income of $149,216 and taxable withdrawals from Haury's Individual Retirement Account ("IRA") totaling...

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