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COLE v. U.S.

No. 87-6016.

863 F.2d 34 (1988)

Jonathan B. COLE; Judith M. Cole, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided December 14, 1988.

Attorney(s) appearing for the Case

Joseph F. Moore, Bigelow, Moore & Tyre, Pasadena, Cal., for plaintiffs-appellants.

James B. Mann, James H. Love, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before HUG, FLETCHER and FARRIS, Circuit Judges.

PER CURIAM:

Jonathan and Judith Cole appeal the district court's dismissal of their tax refund suit for failure to state a claim. The district court rejected the Coles' contention that the IRS tax assessment was time barred. We affirm.

The Coles and the IRS entered into an extension agreement (IRS Form 872-R) giving the IRS until December 31, 1983 to assess a tax for the 1978 tax year. The agreement also provided:

However, we are prohibited from making...

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