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  • Michael O. Egger v. Commissioner of Internal Revenue, 849 F.2d 604, 4th Cir. (1988)

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    The document is a court case from the United States Court of Appeals for the Fourth Circuit regarding a petitioner, Michael O. Egger, appealing a decision by the Tax Court. The Tax Court had determined that Egger was not entitled to an income exclusion under 26 U.S.C. Sec. 911. The Court of Appeals affirmed the Tax Court's decision based on its reasoning. The appeals court found the Tax Court's determination that Egger was not entitled to the income exclusion to be proper based on a review of the record, the Tax Court's opinion, and briefs submitted by the parties. The court dispensed with oral arguments, finding the facts and legal issues were adequately presented in the materials.

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    Filed: 1988-06-06 Precedential Status: Non-Precedential Citations: 849 F.2d 604 Docket: 87-2189

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    The document is a court case from the United States Court of Appeals for the Fourth Circuit regarding a petitioner, Michael O. Egger, appealing a decision by the Tax Court. The Tax Court had determined that Egger was not entitled to an income exclusion under 26 U.S.C. Sec. 911. The Court of Appeals affirmed the Tax Court's decision based on its reasoning. The appeals court found the Tax Court's determination that Egger was not entitled to the income exclusion to be proper based on a review of the record, the Tax Court's opinion, and briefs submitted by the parties. The court dispensed with oral arguments, finding the facts and legal issues were adequately presented in the materials.

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    5 views2 pages

    Michael O. Egger v. Commissioner of Internal Revenue, 849 F.2d 604, 4th Cir. (1988)

    Uploaded by

    Scribd Government Docs
    The document is a court case from the United States Court of Appeals for the Fourth Circuit regarding a petitioner, Michael O. Egger, appealing a decision by the Tax Court. The Tax Court had determined that Egger was not entitled to an income exclusion under 26 U.S.C. Sec. 911. The Court of Appeals affirmed the Tax Court's decision based on its reasoning. The appeals court found the Tax Court's determination that Egger was not entitled to the income exclusion to be proper based on a review of the record, the Tax Court's opinion, and briefs submitted by the parties. The court dispensed with oral arguments, finding the facts and legal issues were adequately presented in the materials.

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    of 2

    849 F.

    2d 604
    Unpublished Disposition

    NOTICE: Fourth Circuit I.O.P. 36.6 states that citation of


    unpublished dispositions is disfavored except for establishing
    res judicata, estoppel, or the law of the case and requires
    service of copies of cited unpublished dispositions of the Fourth
    Circuit.
    Michael O. EGGER, Petitioner-Appellant,
    v.
    COMMISSIONER OF INTERNAL REVENUE, RespondentAppellee.
    No. 87-2189.

    United States Court of Appeals, Fourth Circuit.


    Submitted: March 31, 1988.
    Decided: June 6, 1988.

    Michael O. Egger, appellant pro se.


    Gary Robert Portner Allen, Hirschler, Fleischer, Weinberg, Cox & Allen;
    Richard Farber, Kevin Brown, U.S. Department of Justice; William F.
    Nelson, Chief Counsel, Internal Revenue Service, for appellee.
    Before K.K. HALL, JAMES DICKSON PHILLIPS and MURNAGHAN,
    Circuit Judges.
    PER CURIAM:

    A review of the record, the opinion of the Tax Court, and the informal briefs
    submitted by the parties to this appeal reveals that the Tax Court's
    determination that Michael O. Egger was not entitled to an income exclusion
    pursuant to 26 U.S.C. Sec. 911 was proper. We accordingly affirm the decision
    of the Tax Court based on its reasoning. Egger v. Commissioner, No. 4458-86
    (Tax Ct. Sept. 21, 1987).
    Because the facts and legal contentions are adequately developed in the

    materials before the Court and oral argument would not aid in the decisional
    process, we dispense with argument in this case.
    AFFIRMED.

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