No. 94-70066.

64 F.3d 1406 (1995)

Richard A. CRAMER; Alice D. Cramer; Warren K. Boynton; Susi M. Boynton; Kevin P. Monaghan; Dina A. Monaghan, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 11, 1995.

Attorney(s) appearing for the Case

Michael I. Saltzman, Baker & McKenzie, New York City, for petitioners-appellants Cramer and Boynton.

Robert K. Smith, Robert F. Dailey, Smith & Dailey, La Jolla, CA, for petitioners-appellants Monaghan.

Gary R. Allen, Gilbert S. Rothenberg, Charles Bricken, United States Department of Justice, Tax Division, Washington, DC, for respondent-appellee.

Before: LAY, BRUNETTI, and RYMER, Circuit Judges.

BRUNETTI, Circuit Judge:

Richard and Alice Cramer, Warren and Susi Boynton, and Kevin and Dina Monaghan appeal from a decision of the Tax Court upholding deficiencies and various penalties assessed by the Commissioner of Internal Revenue against their 1982 federal income tax payments. We have jurisdiction pursuant to I.R.C. § 7482(a), and we affirm.


In 1972, Richard Cramer founded IMED Corp., a company that designed...

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