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PALMER v. I.R.S.

No. 95-35297.

116 F.3d 1309 (1997)

Angela PALMER, in her representative capacity as Trustee of the Paul B. Palmer, Jr. Family Preservation Trust, Plaintiff, v. UNITED STATES INTERNAL REVENUE SERVICE, Defendant-Appellee. UNITED STATES of America, Counter-claimant-Appellee, v. Paul B. PALMER, Jr., Counter-defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided July 2, 1997.

Attorney(s) appearing for the Case

Paul B. Palmer, Jr., Kooskia, ID, pro se, for Counter-Defendant-Appellant.

John A. Nolet, Tax Division, United States Department of Justice, Washington, DC, for Defendant-Appellee.

Before: WRIGHT, BRUNETTI and O'SCANNLAIN, Circuit Judges.

O'SCANNLAIN, Circuit Judge:

We must decide whether the Internal Revenue Service made proper deficiency determinations and assessments for unpaid taxes against non-cooperative taxpayers.

I

Paul and Angela Palmer failed to file tax returns from which their income could be determined for the years 1976 through 1979. Internal Revenue Service ("IRS") agents attempted to meet with the Palmers to gather income information, but the Palmers did not attend...

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