Sauey v. C.I.R.

CourtUnited States Courts of Appeals. United States Court of Appeals (11th Circuit)
Citation881 F.2d 1086
PartiesSauey v. Comr. of IRS * * NO. 88-6153
Decision Date11 July 1989

Page 1086

881 F.2d 1086
Sauey
v.
Comr. of IRS **
NO. 88-6153
United States Court of Appeals,
Eleventh Circuit.
JUL 11, 1989

Appeal From: S.D.Fla.

AFFIRMED.

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** Local Rule 36 case.

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6 cases
  • Borchers v. Comm'r of Internal Revenue, Docket No. No. 3576-86.
    • United States
    • United States Tax Court
    • July 19, 1990
    ...F.2d 985 (1st Cir. 1988), affg. T.C. Memo. 1987-223, followed. Sauey v. Commissioner, 90 T.C. 824 (1988), affd. without published opinion 881 F.2d 1086 (11th Cir. 1989), distinguished. [95 T.C. 83] Bernie H. Beaver, for the petitioners.Gail K. Gibson, for the respondent.OPINIONRAUM, JUDGE: ......
  • Glickman v. Commissioner, Docket No. 23822-89.
    • United States
    • United States Tax Court
    • January 6, 1992
    ...Petitioners have relied extensively upon Sauey v. Commissioner [Dec. 44,739], 90 T.C. 824 (1988), affd. without published opinion, 881 F.2d 1086 (11th Cir. 1989). However, Sauey is distinguishable for the same reason that we found it distinguishable in Borchers v. Commissioner [Dec. 46,730]......
  • Hauptli v. C.I.R., 91-9006
    • United States
    • United States Courts of Appeals. United States Court of Appeals (10th Circuit)
    • December 19, 1991
    ...inconsistent, we subscribe to the former phraseology only. Language in Sauey v. Comm'r, 90 T.C. 824, 829 (1988), aff'd without opinion, 881 F.2d 1086 (11th Cir.1989), and Peterson v. Comm'r, 44 T.C.M. (CCH) 674, 679 (1982), indicating that the proper test is whether there is a reasonable ce......
  • Russell v. Commissioner, Docket No. 27660-87.
    • United States
    • United States Tax Court
    • June 12, 1991
    ...on the same ground. For the same reason, we hold that our decision in Sauey v. Commissioner [Dec. 44,739], 90 T.C. 824 (1988), affd. 881 F.2d 1086 (11th Cir. 1989), also cited by petitioners, is 6. The First Circuit does not agree with the McNamara decision in the context of a fixed term le......
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