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HOLLAND v. C.I.R.

No. 86-1647.

835 F.2d 675 (1987)

Edward J. HOLLAND, Jr., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 23, 1987.

Rehearing Denied February 17, 1988.

Attorney(s) appearing for the Case

Stanley H. Pitts, Frederick A. Patmon (argued), Detroit, Mich., for petitioner-appellant.

Jean Owens, Acting Counsel, IRS, Michael L. Paup (Lead Counsel), Roger M. Olsen, Tax Div. — Dept. of Justice, Washington, D.C., Charles E. Brookhart, Joan I. Oppenheimer (argued), for respondent-appellee.

Before ENGEL and KENNEDY, Circuit Judges, and POTTER, District Judge.

PER CURIAM.

This is an appeal from a decision of the United States Tax Court redetermining the income tax deficiency and determining additions to the tax liability of petitioner-appellant Edward J. Holland, Jr. The Tax Court's opinion is published at Holland v. Commissioner, 51 T.C.M. (CCH) 172 (1985).

On July 14, 1982 the Internal Revenue Service sent Holland a notice of deficiency for the 1977 and 1978 tax years disallowing...

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