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RAVETTI v. U.S.

No. 92-15883.

37 F.3d 1393 (1994)

Estate of Silvio RAVETTI, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided October 11, 1994.

Attorney(s) appearing for the Case

Richard H. Foster, Salinas, CA, for plaintiff-appellant.

Mary Frances Clark, Tax Div., U.S. Dept. of Justice, Washington, DC, for defendant-appellee.

Before: GOODWIN, O'SCANNLAIN and KLEINFELD, Circuit Judges.

KLEINFELD, Circuit Judge:

The Estate of one spouse sued in district court to challenge the IRS determination that the other spouse was "innocent" of liability on the joint returns.

FACTS

Silvio and Martha Ravetti were divorced in 1982. They agreed to share tax liability arising out of past returns, and specifically provided for how to apportion liability if Martha were determined to be an "innocent spouse." Silvio died in 1986. Meanwhile, Martha...

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