Buddy L. Snead and Ligaya Snead v. Commissioner of Internal Revenue

This three-judge panel has determined unanimously that oral argument would not be of material assistance in the determination of this appeal. See Fed.R.App.P. 34(a); Tenth Circuit R. 10(e). The cause is therefore ordered submitted without oral argument.

This is an appeal from the decision of the tax court granting judgment on the pleadings in favor of the Commissioner. Petitioners brought the underlying action in the tax court for a redetermination of deficiencies assessed for the tax years 1978 and 1979.

Examination of the petition reveals that petitioners have failed to state any nonfrivolous…