SCAR v. C.I.R.

No. 85-7212.

814 F.2d 1363 (1987)

Howard S. SCAR and Ethel M. Scar, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 14, 1987.


Attorney(s) appearing for the Case

Mark Bernsley, Los Angeles, Cal., for petitioners-appellants.

Francis Allegra, David I. Pincus, Washington, D.C., for respondent-appellee.

Before FLETCHER, NELSON and CYNTHIA HOLCOMB HALL, Circuit Judges.


FLETCHER, Circuit Judge:

Taxpayers Howard and Ethel Scar petition for review of the Tax Court's denial of their motion to dismiss for lack of jurisdiction and denial of their two summary judgment motions. Taxpayers argue that the Tax Court lacked jurisdiction because the Commissioner of the Internal Revenue Service (IRS) issued an invalid notice of deficiency. Alternatively, they argue that the Tax Court incorrectly denied their motions for summary judgment and should...

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