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ROBERTS v. C.I.R.

Nos. 12111, 12253.

398 F.2d 340 (1968)

Edward Lee ROBERTS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Richard Lee PLOWDEN and Dale T. Plowden, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided June 20, 1968.

Certiorari Denied November 12, 1968.

Attorney(s) appearing for the Case

Edward Lee Roberts and Richard Lee Plowden, pro se on briefs for petitioners.

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Gilbert E. Andrews, and Marco S. Sonnenschein, Attys., Dept. of Justice, on brief, for respondent.

Before HAYNSWORTH, Chief Judge, and SOBELOFF and BOREMAN, Circuit Judges.

Certiorari Denied November 12, 1968. See 89 S.Ct. 297.

PER CURIAM:

The decision of the Tax Court1 is affirmed.

Taxpayers believe themselves wronged in the instant case because of a basic misunderstanding as to the interaction of §§ 172 and 1374 of the Internal Revenue Code of 1954.2 They argue that § 172 takes precedence over § 1374 and entitles them to a larger net operating...

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