Court of Appeals for the First Circuit June 10, 1998, 97-2380 (Clayton v. Internal Revenue)

USCA1 Opinion [NOT FOR PUBLICATION--NOT TO BE CITED AS PRECEDENT] United States Court of Appeals For the First Circuit No. 97-2380 FREDERIC S. CLAYTON and MARLENE B. CLAYTON, Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee. ON APPEAL FROM THE DECISION OF THE UNITED STATES TAX COURT Before Selya, Circuit Judge, Rosenn* and Campbell, Senior Circuit Judges.