Gajda v. CIR

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT _______________ No. 97-60732 Summary Calendar _______________ JOSEPH J. GAJDA and LILLIAN A. GAJDA, Petitioners-Appellants, VERSUS COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. _________________________ Appeal from a Decision of the United States Tax Court _________________________ August 7, 1998 Before JONES, SMITH, and STEWART, Circuit Judges. JERRY E. SMITH, Circuit Judge:* Joseph Gajda, who files tax returns jointly with his wife Lillian Gajda, appeals the Tax Court’s summary judgment on Joseph’s claim that $91,690 of…