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SILVERMAN v. C.I.R.

No. 95-2062.

86 F.3d 260 (1996)

David R. SILVERMAN, et al., Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided June 20, 1996.

Attorney(s) appearing for the Case

James P. Redding, with whom Gail E. Pergine and James P. Redding & Associates were on brief, Providence, for petitioners, appellants.

Kenneth W. Rosenberg, Attorney, Tax Division, Department of Justice, Arlington, VA, with whom Loretta C. Argrett, Assistant Attorney General, and Gary R. Allen, Kenneth L. Greene, and Patricia M. Bowman, Attorneys, Tax Division, Department of Justice, Washington, DC, were on brief, for respondent, appellee.

Before CYR, Circuit Judge, ALDRICH, Senior Circuit Judge, and GERTNER, United States District Judge.

CYR, Circuit Judge.

Petitioners David and Meredith Silverman appeal a United States Tax Court ruling rejecting their claim that the statute of limitations barred further tax assessments by the Internal Revenue Service ("IRS"). We affirm the tax court decision.

I

BACKGROUND

The Silvermans jointly reported losses from a limited partnership interest in a motion picture production company for tax years 1975, 1976, and 1977. Petitioner...

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