Patrick Selliott; Donna Jelliott v. Commissioner of Internal Revenue

* Pursuant to 5TH CIR. R. 47.5, the court has determined
that this opinion should not be published and is not precedent
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:*

-- 1 of 2 --

except under the limited circumstances set forth in 5TH CIR. R.
47.5.4.
2
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.

-- 2 of 2 --