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ZACK v. C.I.R.

No. 00-2375.

291 F.3d 407 (2002)

William D. ZACK, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed May 21, 2002.

Attorney(s) appearing for the Case

William D. Zack, Troy, MI, for Petitioner-Appellant.

Ann B. Durney (briefed), Patricia Bowman, Randolph L. Hutter (briefed), U.S. Department of Justice, Appellate Section Tax Division, Washington, DC, for Respondent-Appellee.

Before: MERRITT, SUHRHEINRICH, and GILMAN, Circuit Judges.

OPINION

GILMAN, Circuit Judge.

William D. Zack challenges the determination made by the Commissioner of Internal Revenue that Zack is liable (1) for income tax deficiencies for the tax years 1985 and 1986 based upon unreported income, and (2) for additions to tax for fraud and substantial understatement of tax with regard to the deficiencies for those years. Although Zack does not contend that his income tax returns for 1985 and 1986 were accurate, he argues...

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