Thomas v. Cassidy v. Commissioner of Internal Revenue

RIPPLE, Circuit Judge.

In this case, appellant-taxpayer Thomas V. Cassidy, appeals from the order and decision of the United States Tax Court granting summary judgment for the Commissioner with respect to income tax deficiencies and fraud penalties. For the reasons set forth in this opinion, we affirm the judgment of the tax court.

I

Facts

On June 24, 1980, the Commissioner of Internal Revenue sent the appellant a notice of deficiency in federal income taxes for the fiscal years ending August 31, 1974 and August 31, 1975. These deficiencies were in the amounts of $12,865 and $22,-028,…