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ZIMMER v. CONNETT

Nos. 79-3048, 79-3734.

640 F.2d 208 (1981)

David H. ZIMMER and Carolyn J. Zimmer, Petitioners-Appellants, v. William H. CONNETT, District Director, Internal Revenue Service, Respondent-Appellee. Joseph VALLERAND and Roberta W. Vallerand, Petitioners-Appellants, v. William H. CONNETT, District Director, Internal Revenue Service, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 17, 1981.

Attorney(s) appearing for the Case

Clyde R. Maxwell, New Port Beach, Cal., on brief; Morgan C. Taylor, New Port Beach, Cal., argued, for petitioners-appellants.

M. Carr Ferguson, Washington, D. C., on brief; William A. Whitledge, Washington, D. C., argued, for respondent-appellee.

Before TRASK, SNEED and SCHROEDER, Circuit Judges.

SNEED, Circuit Judge:

The Internal Revenue Service (I.R.S. or Service), pursuant to 26 U.S.C. § 7605(b), previously audited taxpayers Zimmer's 1975 joint income tax return and taxpayers Vallerand's 1975 and 1976 joint income tax returns. Thereafter, it notified taxpayers that it found it necessary to reexamine taxpayers' books and records for those years. Taxpayers petitioned the District Director to revoke the notice of reexamination or to grant them a hearing...

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