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SLIWA v. C.I.R.

No. 86-7430.

839 F.2d 602 (1988)

Sylvia A. SLIWA, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided February 12, 1988.

Attorney(s) appearing for the Case

Paul J. Mooney and Marc L. Spitzer, Phoenix, Ariz., for petitioner-appellant.

Michael L. Paup, Gilbert S. Rothenberg and John A. Dudeck, Jr., Washington, D.C., for respondent-appellee.

Before POOLE and BOOCHEVER, Circuit Judges, and DIMMICK, District Judge.

POOLE, Circuit Judge:

This case arises out of alleged deficiencies in the 1975, 1976, and 1977 federal income tax paid by appellant Sylvia Sliwa. After Ms. Sliwa filed a petition in the tax court seeking a re-determination of the deficiencies set forth by the Commissioner, the Commissioner of Internal Revenue conceded that Sliwa's return was not in fact deficient, and stipulated to the dismissal of the Notice of Deficiency against her.

Sliwa then applied to...

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