KELLEY v. C.I.R.

Nos. 93-70867, 94-70113.

45 F.3d 348 (1995)

David M. KELLEY; David M. Kelley, Executor; Estate of Nancy I. Kelley, Deceased, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. David M. KELLEY; Mary L. Kelley, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided January 23, 1995.


Attorney(s) appearing for the Case

Arthur H. Boelter, Boelter & Gale, Seattle, WA, for petitioners-appellants.

Bridgett M. Rowan and Marion E.M. Erickson, Tax Div., U.S. Dept. of Justice, Washington, DC, for respondent-appellee.

Before: NOONAN, O'SCANNLAIN, and LEAVY, Circuit Judges.


LEAVY, Circuit Judge:

In these consolidated appeals we are called upon to determine whether the United States Tax Court ("Tax Court") possesses the equitable power to reform consent-to-extend agreements entered into between taxpayers and the revenue collecting arm of the federal government. For the reasons which follow, we conclude that the Tax Court has a limited equitable power to reform such agreements, so long as they are properly before the Tax Court in the exercise...

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