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Estate of Mary Mason, Deceased, Herbert L. Harris, Administrator, and Robert Mason v. Commissioner of Internal Revenue , 566 F.2d 2 ( 1977 )


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  • 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