Frank A. Fazzio v. Commissioner of Internal Revenue

Sixth Circuit

Frank A. Fazzio v. Commissioner of Internal Revenue

959 F.2d 630, 69 A.F.T.R.2d (RIA) 1055, 1992 U.S. App. LEXIS 5779, 1992 WL 62785

CourtCourt of Appeals for the Sixth Circuit

DecidedApril 2, 1992

Docket91-1834

StatusPublished

Cited by6 cases

This text of 959 F.2d 630 (Frank A. Fazzio v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Frank A. Fazzio v. Commissioner of Internal Revenue, 959 F.2d 630, 69 A.F.T.R.2d (RIA) 1055, 1992 U.S. App. LEXIS 5779, 1992 WL 62785 (6th Cir. 1992).

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Opinion

PER CURIAM.

Petitioner-appellant, Frank A. Fazzio (“appellant”), appeals from the tax court’s April 16, 1991, order and decision, which held that appellant was deficient in his payment of income tax for the 1984 taxable year and ordered payment by appellant for additional taxes pursuant to I.R.C. §§ 6653(b)(l)-{2), 6661. Finding that appellant’s deficiency was a “substantial underpayment attributable to a tax-motivated transaction,” the tax court further ordered appellant to pay interest on the deficiency pursuant to I.R.C. § 6621(c).

Having carefully considered the record and the arguments presented in the briefs and orally, we find no error warranting reversal. We, therefore, AFFIRM the order of the Honorable L.W. Hamblen, Judge for the United States Tax Court, for the reasons set forth in his April 16, 1991, decision, made pursuant to the tax court’s December 3, 1990, and March 21, 1991, memorandum opinions.

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PER CURIAM.

Petitioner-appellant, Frank A. Fazzio (“appellant”), appeals from the tax court’s April 16, 1991, order and decision, which held that appellant was deficient in his payment of income tax for the 1984 taxable year and ordered payment by appellant for additional taxes pursuant to I.R.C. §§ 6653(b)(l)-{2), 6661. Finding that appellant’s deficiency was a “substantial underpayment attributable to a tax-motivated transaction,” the tax court further ordered appellant to pay interest on the deficiency pursuant to I.R.C. § 6621(c).

Having carefully considered the record and the arguments presented in the briefs and orally, we find no error warranting reversal. We, therefore, AFFIRM the order of the Honorable L.W. Hamblen, Judge for the United States Tax Court, for the reasons set forth in his April 16, 1991, decision, made pursuant to the tax court’s December 3, 1990, and March 21, 1991, memorandum opinions.

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959 F.2d 630, 69 A.F.T.R.2d (RIA) 1055, 1992 U.S. App. LEXIS 5779, 1992 WL 62785, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frank-a-fazzio-v-commissioner-of-internal-revenue-ca6-1992.

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