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CORREIA v. COMMISSIONER OF INTERNAL REVENUE

No. 94-70022.

58 F.3d 468 (1995)

Vernon L. CORREIA; Charlotte M. Correia, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 23, 1995.

Attorney(s) appearing for the Case

Christopher L. Haberman, Bourdette & Parters, Visalia, CA, for petitioners-appellants.

Gary R. Allen, Gilbert S. Rothenberg, Andrea R. Tebbets, U.S. Dept. of Justice, Tax Div., Washington, DC, for respondent-appellee.

Before: GOODWIN, FARRIS and KLEINFELD, Circuit Judges.

PER CURIAM:

Taxpayers Vernon L. Correia and Charlotte M. Correia timely appeal the Tax Court's dismissal of their petition for redetermination of deficiency. The Tax Court dismissed the petition for lack of jurisdiction. We review de novo, Billingsley v. Commissioner, 868 F.2d 1081, 1084 (9th Cir.1989), and affirm.

I. BACKGROUND

The Commissioner of Internal Revenue issued a statutory notice of deficiency to...

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