Luther R. Patton v. Commissioner of Internal Revenue

JOHNSON, Circuit Judge:

Luther R. Patton seeks review of a tax court judgment upholding tax deficiencies and fraud penalties assessed by the Commissioner of Internal Revenue (“Commissioner”). Finding Patton’s contentions on appeal unpersuasive, we affirm the judgment of the tax court.

I

In 1967, Luther Patton was elected sheriff of Harrison County, Mississippi. As sheriff, Patton was the county’s chief law enforcement officer and tax collector. During the period Patton was in office, a Mississippi sheriff would run his office much like an ordinary business venture. The sheriff received fees for…