Elliott v. CIR

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:* * Pursuant to 5TH CIR. R. 47.5, the court has determined that this opinion should not be published and is not precedent The notices of deficiency were not so inadequate as to deprive the Tax Court of jurisdiction, and they were sufficient to inform the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. except under the limited circumstances set forth in 5TH CIR. R. 47.5.4. 2