Powell v. Commissioner

PUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT ALLAN R. POWELL; JOAN K. POWELL, Petitioners-Appellants, v. No. 96-2549 COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. RICHARD J. MONTGOMERY; ADELE S. MONTGOMERY, Petitioners-Appellants, No. 96-2554 v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Appeals from the United States Tax Court. (Tax Ct. Nos. 93-3499, 96-8028) Argued: June 6, 1997 Decided: October 16, 1997 Before HAMILTON and LUTTIG, Circuit Judges, and GARBIS, United States District Judge for the District of Maryland, sitting by designation.…