Court of Appeals for the Sixth Circuit November 14, 1990, 89-2313 (Jack C. Chilingirian Joann E. Chilingirian v. Commissioner of Internal Revenue)

BOYCE F. MARTIN, Jr., Circuit Judge.

Jack and Joann Chilingirian appeal the tax court’s decision of August 14, 1989, based on its opinion reported at T.C. Memo 1986-463, 52 T.C.M. (CCH) 606 (Sept. 22, 1986), holding them liable for deficiencies in their federal income taxes for tax years 1978, 1979 and 1980. We affirm.