Melvin Williams Mary Williams v. Commissioner of Internal Revenue

OPINION

MURNAGHAN, Circuit Judge:

Taxpayers Melvin and Mary Williams have appealed the United States Tax Court’s assessments of tax deficiencies against them. The Internal Revenue Service (IRS), using documents, cash and valuable items seized from the Taxpayers’ residence in connection with a grand jury investigation of possible criminal violations of federal narcotics laws — - an investigation that never yielded an indictment — applied the “source and application of funds method” to determine tax deficiencies for the years 1980 through 1984. The Taxpayers as Appellants have challenged the…