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CONFORTE v. C.I.R.

Nos. 81-7573, 81-7576.

692 F.2d 587 (1982)

Sally CONFORTE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Joseph CONFORTE, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided November 5, 1982.

Stay Denied January 12, 1983.

Attorney(s) appearing for the Case

Bruce I. Hochman, Beverly Hills, Cal., for petitioner-appellant.

Farley P. Katz, Washington, D.C., argued, Michael L. Paup, Farley P. Katz, Washington, D.C., on brief, for respondent-appellee.

Before MERRILL, Senior Circuit Judge, KASHIWA and WALLACE, Circuit Judges.

Stay Denied January 12, 1983. See 103 S.Ct. 663.

WALLACE, Circuit Judge:

Joseph and Sally Conforte appeal from a decision of the tax court sustaining tax deficiencies and penalties which had been assessed against them for the calendar years 1973 through 1976. Conforte v. Commissioner, 74 T.C. 1160 (1980). Jurisdiction is based on 26 U.S.C. § 7482. They question the tax court's failure to limit their tax payments...

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