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566 F2d 2 Estate Mason v. Commissioner of Internal Revenue

566 F.2d 2

78-1 USTC P 9162

ESTATE of Mary MASON, Deceased, Herbert L. Harris,
Administrator, and Robert Mason, Petitioners-Appellants,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

No. 76-1667.

United States Court of Appeals,
Sixth Circuit.

Dec. 14, 1977.

1

Henry A. Bornstein, Bornstein & Wishnow, Southfield, Mich., for petitioners-appellants.

2

Scott P. Crampton, Gilbert Andrews, Asst. Attys. Gen., Tax Div., U. S. Dept. of Justice, Washington, D. C., Meade Whitaker, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

ORDER

3

Before EDWARDS and ENGEL, Circuit Judges, and THORNTON,* Senior District Judge.

4

On receipt and consideration of an appeal from a Tax Court decision determining an income tax deficiency for 1966 and 1967 totaling $51,616.65, plus a negligence penalty of $2,580.83.

5

The judgment of the Tax Court is affirmed for the reasons set forth in the opinion of the Tax Court reported at 64 T.C. 651.

*

Honorable Thomas P. Thornton, Senior United States District Judge for the Eastern District of Michigan, Southern Division, sitting by designation