Court of Appeals for the Fourth Circuit August 16, 1977, 76-1925 (Robert F. Koch and Evelyn C. Koch v. Donald C. Alexander, Commissioner of Internal Revenue)

PER CURIAM:

The issue in this appeal is whether the filing of an amended income tax return revealing zero tax liability (after first filing a return showing liability in excess of $20,-000) renders the amount of tax disclosed in the taxpayer’s original return, and previously- assessed by IRS, a “deficiency” as defined by IRC § 6211,

1

and incorporated into § 6213(a).

2

26 U.S.C. §§ 6211, 6213(a).