Unpublished Dispositionnotice: Sixth Circuit Rule 24(c) States That Citation of Unpublished Dispositions is Disfavored Except for Establishing Res Judicata, Estoppel, or the Law of the Case and Requires Service of Copies of Cited Unpublished Dispositions of the Sixth Circuit, 937 F.2d 609 (6th Cir. 1991)Annotate this Case
Nos. 90-1400, 90-1401.
United States Court of Appeals, Sixth Circuit.
July 10, 1991.
Before NATHANIEL R. JONES and RYAN, Circuit Judges, and McRAE, Senior District Judge.*
Petitioners Hallison H. Young and Peggy Young filed suit in the United States Tax Court challenging the Commissioner of the Internal Revenue Service's determinations that there were deficiencies of $11,343.58, $4,801.00, $10,058.00, and $13,371.00 for the tax years 1978, 1979, 1980, and 1981, respectively. The Tax Court upheld the Commissioner's determinations, including additions to taxes. Petitioners now seek review of the Tax Court's decisions.
Having carefully considered the record on appeal and the briefs of the parties, with the additional benefit or oral argument, we are unable to say that the Tax Court erred.
Taxpayers have been embroiled in litigation regarding their tax liability since the early 1980s. In a number of separate appeals, this court has already considered many issues concerning the Internal Revenue Service's investigation into taxpayers' federal income tax liability.1
There are no novel issues of merit presented in these appeals. Because the Tax Court articulated the reasons for its determinations, and we find those determinations to be correct in all respects, the issuance of a written opinion by this court would be duplicative and serve no purpose.
Accordingly, the decisions of the Tax Court are affirmed upon the reasoning set out by that court in its memorandum opinions filed on September 5 and 6, 1989.
The Honorable Robert M. McRae, Senior United States District Judge for the Western District of Tennessee, sitting by designation