566 F.2d 2
78-1 USTC P 9162
ESTATE of Mary MASON, Deceased, Herbert L. Harris,
Administrator, and Robert Mason, Petitioners-Appellants,
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals,
Dec. 14, 1977.
Henry A. Bornstein, Bornstein & Wishnow, Southfield, Mich., for petitioners-appellants.
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.
Before EDWARDS and ENGEL, Circuit Judges, and THORNTON,* Senior District Judge.
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.
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