ZAPARA v. C.I.R.

No. 08-74173.

652 F.3d 1042 (2011)

Michael A. ZAPARA; Gina A. Zapara, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed July 18, 2011.


Attorney(s) appearing for the Case

Nathan J. Hochman, Assistant Attorney General; Gilbert S. Rothenberg, Acting Deputy Assistant Attorney General; Michael J. Haungs and Steven Parks, Attorneys, Tax Division, Department of Justice; Washington, D.C., for the appellant.

Aimee A. Feinberg and Paul J. Katz, Munger, Tolles & Ollson LLP; San Francisco, CA, for the appellees.

Before: MARY M. SCHROEDER and SIDNEY R. THOMAS, Circuit Judges, and LYNN S. ADELMAN, District Judge.


OPINION

THOMAS, Circuit Judge:

This appeal presents the question, inter alia, of whether the Tax Court had jurisdiction in a hearing conducted pursuant to 26 U.S.C. § 6330 to review the Internal Revenue Service's failure to comply with its statutory mandate under 26 U.S.C. § 6335(f). We conclude that it did, and we affirm the judgment of the Tax Court.

I

Michael and Gina Zapara owe the IRS over $450,000 for failing to report...

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