Elliott vs. CIR, (5th Cir. 2002)
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IN THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT
No. 02-60077
PATRICK S ELLIOTT; DONNA J ELLIOTT
Petitioners - Appellants
v. COMMISSIONER OF INTERNAL REVENUE
Respondent - Appellee
No. 02-60078
LARRY ELLIOTT; JULIE F ELLIOTT
Petitioners - Appellants
v. COMMISSIONER OF INTERNAL REVENUE
Respondent - Appellee
Appeals from the Decision of the
United States Tax Court
(19425-98 & 19433-98)
November 7, 2002
Before KING, Chief Judge, and JOLLY and HIGGINBOTHAM, Circuit
Judges.
PER CURIAM:* The notices of deficiency were not so inadequate as to deprive the Tax Court of jurisdiction, and they were sufficient to inform the Elliotts that their claimed business expense deductions had not been allowed. That said, the Internal Revenue Service clearly could have done considerably better and thereby saved all involved, including the Tax Court and this court, from this wasteful exercise.
AFFIRMED.
* Pursuant to 5TH CIR. R. 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5TH CIR. R.
47.5.4.
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