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KEADO v. U.S.

Nos. 86-1312, 87-1725 and 87-4752.

853 F.2d 1209 (1988)

Conrad KEADO, et al., Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. Conrad L. KEADO and Linda W. Keado, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

September 1, 1988.

Attorney(s) appearing for the Case

Ronald M. Mankoff, G. Tomas Rhodus, Ronald A. Stein, Brice & Mankoff, Dallas, Tex., for Conrad L. Keado and Linda W. Keado.

Martha B. Brissette, Tax Div., U.S. Dept. of Justice, Washington, D.C., Marvin Collins, U.S. Atty., Dallas, Tex., David English Carmack, Tax Div., U.S. Dept. of Justice, Washington, D.C., for U.S.

Martha B. Brissette, David English Carmack, Tax Div., U.S. Dept. of Justice, Washington, D.C., for C.I.R.

Before GOLDBERG, GARWOOD and JOLLY, Circuit Judges.

GOLDBERG, Circuit Judge:

The plaintiffs appeal from a federal district court decision denying their request for an injunction barring collection of deficiencies asserted by the Internal Revenue Service. They also appeal from a Tax Court decision dismissing their petition on the ground that it was not timely filed. Finding both decisions correct, we affirm.

I. BACKGROUND

The Internal Revenue Service ("IRS") audited the 1980 and 1981 tax returns filed...

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