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BAXTER v. C.I.R. SERVICE

No. 17-2402.

910 F.3d 150 (2018)

Guy R. BAXTER; Lonnie C. Baxter, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided: December 7, 2018.

Attorney(s) appearing for the Case

ARGUED: David Decoursey Aughtry , CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY, Atlanta, Georgia, for Appellants. Jennifer Marie Rubin , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. ON BRIEF: Jasen D. Hanson , CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY, Atlanta, Georgia, for Appellants. Richard E. Zuckerman , Principal Deputy Assistant Attorney General, Gilbert S. Rothenberg , Arthur T. Catterall , Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Affirmed by published opinion. Judge Wynn wrote the opinion, in which Judge King and Judge Duncan joined.

Taxpayers Lonnie Curtis Baxter ("Ms. Baxter") and her husband Guy R. Baxter (collectively, with Ms. Baxter, "Taxpayers") appeal an opinion and decision of the United States Tax Court imposing back taxes and penalties attributable to Taxpayers' use of what appellee Commissioner of Internal Revenue (the "Commissioner") deemed...

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