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SAMPSON v. C.I.R.

No. 82-1373.

710 F.2d 262 (1983)

William C. SAMPSON and Lucille A. Sampson, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided June 23, 1983.

Attorney(s) appearing for the Case

Michael G. Parham (argued), Talking Rock, Ga., for petitioners-appellants.

Kenneth W. Gideon, Chief Counsel, I.R.S., John H. Menzel, Glenn L. Archer, Jr., Michael L. Paup, Ann Belanger Durney, David I. Pincus (argued), Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before CONTIE and KRUPANSKY, Circuit Judges, and GUY, District Judge.

PER CURIAM.

The Lucille A. Sampson Pure Equity Trust (Trust) appeals the Tax Court's denial of a petition to intervene in tax deficiency litigation between the Commissioner of Internal Revenue and William and Lucille Sampson. For the reasons stated below, we vacate the Tax Court's decision and remand for further proceedings.

The Commissioner sent a notice of deficiency to William and Lucille Sampson in their individual capacities. The Sampsons, who also are...

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