Rawlin L. Stovall v. Commissioner of Internal Revenue

JOHN W. PECK, Senior Circuit Judge:

Appellant Rawlin Stovall appeals from the decision of the United States Tax Court determining a deficiency of $1,386,664 and additions to tax of $346,666 and $69,333 in his 1972 tax year. This court has jurisdiction under 26 U.S.C. § 7482. For the reasons set forth below, we affirm.

In 1972, Stovall was the president and principal shareholder of Stovall and Stovall, Inc., a futures commission merchant registered under the Commodity Exchange Act. He also transacted business in his individual capacity under the name R.L. Stovall, Sole Proprietor, Principal in…