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PURER v. U.S.

No. 88-5870.

872 F.2d 277 (1989)

Phillip PURER; Winifred Purer, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Memorandum March 6, 1989.

Opinion April 4, 1989.

Attorney(s) appearing for the Case

Willard D. Horwich, Horwich & Main, Los Angeles, Cal., for plaintiffs-appellants.

Barbara I. Hodges, Asst. Atty. Gen., Tax Div., Washington, D.C., for defendant-appellee.

Before FLETCHER, PREGERSON and LEAVY, Circuit Judges.

LEAVY, Circuit Judge:

In this appeal from the district court's denial of a claim for refund of allegedly overpaid income taxes, the appellants contend that the Internal Revenue Service misinterpreted a statute that changed the manner in which interest on deficiencies was calculated, and was estopped from claiming a portion of the accumulated interest on the appellants' tax deficiency. We review de novo, see First American Title Ins. Co. v. United States,

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