United States Fifth Circuit
ALFARO v. COMM'R. OF INTERNAL REVENUE, 03-60261
The Tax Court's ruling, upholding a notice of deficiency, is affirmed where the Treasury Regulation is valid, and its rule - that an individual's income tax liability, regardless of the nature of the income giving rise to the liability, is a personal, non-business obligation, so that interest owed by the individual for failing to pay his tax obligations is also personal - is reasonable.
Appellate Information
- Decided 11/06/2003
- Published 11/06/2003
Judges
- WIENER, Circuit Judge:, Before JOLLY, SMITH, and WIENER, Circuit Judges.
Court
- United States Fifth Circuit
Counsel
- For Appellant:
- Howard P. Newton,Matthews & Branscomb, San Antonio, TX, Kenton E. McDonald, Matthews & Branscomb, Corpus Christi, TX, for Petitioners-Appellants.
- For Appellees:
- Randolph Lyons Hutter, Jonathan S. Cohen, U.S. Dept. of Justice, Tax Div., Charles Casazza, Clerk, U.S. Tax Court, B. John Williams, Jr., IRS, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Washington, DC, for Respondent-Appellee.