SPONZA v. C.I.R.

No. 86-7432.

844 F.2d 689 (1988)

Marilyn SPONZA, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided April 19, 1988.


Attorney(s) appearing for the Case

Karen Hawkins, Taggart and Hawkins, San Francisco, Cal., for petitioner-appellant.

Gilbert Rothenberg, Dept. of Justice, Washington, D.C., for respondent-appellee.

Before CANBY and NORRIS, Circuit Judges, and HUPP, District Judge.


HUPP, District Judge:

This matter is before the court on appeal from an order of the Tax Court denying a motion for fees and costs for lack of jurisdiction.

1. Factual background. Appellant Marilyn Sponza filed a joint income tax return with her then husband for the taxable year 1978. Thereafter, the Internal Revenue Service (hereafter "IRS") audited the return and determined that there was a deficiency. A notice of deficiency was sent to appellant...

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