DISCLAIMER:  Any unofficial case summaries below are prepared by the clerk's office
                        as a courtesy to the reader. They are not part of the opinion of the court.

963828P.pdf   07/08/1998  Horace R. Walter  v.  United States
   U.S. Court of Appeals Case No:  96-3828
   District of South Dakota   
   Federal tax; Concept of constructive receipt for tax
   purposes discussed; penalty for substantial understatement
   affirmed.