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PACK v. U.S.

No. 92-16837.

992 F.2d 955 (1993)

Ronald L. PACK, and Marla Pack, For themselves and as Representatives of a Class, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 5, 1993.

Attorney(s) appearing for the Case

Harry J. Kaplan, San Jose, CA, for plaintiffs-appellants.

Teresa McLaughlin, Asst. U.S. Atty., Tax Div., Washington, DC, for defendant-appellee.

Before: GOODWIN, NOONAN, and T.G. NELSON, Circuit Judges.

T.G. NELSON, Circuit Judge:

I

OVERVIEW

In order to resolve a dispute with the Internal Revenue Service (IRS) regarding the tax treatment of certain partnership property, Ronald and Marla Pack (the Packs) executed a closing agreement with the IRS. The Packs filed this suit against the United States (Government) seeking a tax refund for interest assessed on their tax deficiency. They contend that the closing agreement suspended the assessment of...

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