Court of Appeals for the Fifth Circuit August 28, 2000, 99-60074 (Payne v. CIR)

Revised August 22, 2000

IN THE UNITED STATES COURT OF APPEALS

FOR THE FIFTH CIRCUIT

No. 99-60074

JERRY S. PAYNE,

Petitioner-Appellant,

versus

COMMISSIONER OF INTERNAL REVENUE,

Respondent-Appellee.

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Appeal from the Decision of the

United States Tax Court

_____________

August 17, 2000

Before JONES, DUHÉ, and WIENER, Circuit Judges.

WIENER, Circuit Judge:

Petitioner-Appellant Jerry S.