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KINSEY v. C.I.R.

No. 87-7237.

859 F.2d 1361 (1988)

William H. KINSEY, and Estate of Irene S. Kinsey, Deceased, William H. Kinsey, Executor, Plaintiffs-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided October 19, 1988.

Attorney(s) appearing for the Case

William H. Kinsey, Portland, Or., pro se, and for plaintiffs-appellants.

Barbara I. Hodges, Atty., Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before GOODWIN, Chief Judge, ALARCON, Circuit Judge, and TASHIMA, District Judge.

TASHIMA, District Judge:

This appeal from the Tax Court involves income taxes payable for the years 1977 and 1978.1 Only two issues are presented on appeal: (1) whether the deficiency notices for 1977 were timely issued by the Internal Revenue Service (the "Service" or "I.R.S."); and (2) whether the deficiencies determined in the 1977 notices were within the restriction contained in the Form 872-A executed by the parties.

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