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LITTFIN v. C.I.R.

Nos. 93-9001, 93-9006 and 93-9008.

17 F.3d 1345 (1994)

Robert J. LITTFIN and Evelyn K. Littfin; Gilbert J. McGough and Carol M. McGough; and Russell P. Kramer, Jr. and Sharon D. Kramer, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

March 1, 1994.

Attorney(s) appearing for the Case

Declan J. O'Donnell of Declan Joseph O'Donnell, P.C., Englewood, Colorado, for petitioners-appellants.

Kevin M. Brown, Attorney (Michael L. Paup, Acting Assistant Attorney General; David I. Pincus, Attorney; and Christine A. Grant, Attorney (in 93-9006), with him on the briefs); Tax Division, Department of Justice, Washington, D.C., for respondent-appellee.

Before KELLY and McKAY, Circuit Judges, and SEAY, Chief District Judge.

McKAY, Circuit Judge.

Robert and Evelyn Littfin, Gilbert and Carol McGough, and Russell and Sharon Kramer (collectively, "taxpayers"), Appellants in the above-captioned cases, appeal from orders of the United States Tax Court holding that it lacked jurisdiction over Appellants' petitions for redetermination of interest on tax deficiencies. Because the three cases arise from the same circumstances, we consolidated the appeals.

In 1984, 1986, and 1989, the Commissioner...

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