Edward J. Nagourney; Louise P. Nagourney, Petitioners-appellants, v. Commissioner of Internal Revenue, Respondent-appellee, 904 F.2d 700 (4th Cir. 1990)

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US Court of Appeals for the Fourth Circuit - 904 F.2d 700 (4th Cir. 1990) Argued: April 2, 1990. Decided: May 23, 1990

On Appeal from the United States Tax Court. (No. 86-12771).

Clifford A. Coppola, Clark & Stant, P.C., Virginia Beach, Va., argued, for appellants; Thomas R. Frantz, CLARK & STANT, P.C., Virginia Beach, Virginia, on brief

Joel Adam Rabinovitz, Tax Division, United States Department of Justice, Washington, D.C., for Appellee; Shirley D. Peterson, Assistant Attorney General, Gary R. Allen, Richard Farber, Tax Division, United States Department of Justice, Washington, D.C., on brief.

USTC

AFFIRMED.

Before ERVIN, Chief Judge, K.K. HALL, Circuit Judge, and BUTZNER, Senior Circuit Judge.

PER CURIAM:


Edward J. Nagourney and Louise P. Nagourney appeal from a decision of the United States Tax Court upholding the Commissioner's determination of a $140,161 deficiency in their 1983 federal income tax. After review of the briefs and record, and after consideration of oral argument, we find this appeal to be without merit. Accordingly, we affirm the decision below for the reasons stated by the Tax Court. Nagourney v. Commissioner of Internal Revenue, T.C. Memo 1989-339 (July 17, 1989).

AFFIRMED

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