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ESTATE OF RAY v. C.I.R.

No. 96-60322.

112 F.3d 194 (1997)

ESTATE OF Donald H. RAY, Deceased; Patricia G. Ray, Independent Executrix, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Cipriano DOMINGUEZ; Estate of Isabel Dominguez, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

May 8, 1997.

Attorney(s) appearing for the Case

Thomas E. Redding, Sallie W. Gladney, Redding & Associates, Houston, TX, for Petitioners-Appellants.

Paula Keyser Speck, Teresa Ellen McLaughlin, U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, Stuart L. Brown, Chief Counsel, I.R.S., Washington, DC, for Respondent-Appellee.

Before JONES, STEWART and DENNIS, Circuit Judges.

STEWART, Circuit Judge:

Taxpayers appeal the tax court's decision that the Commissioner of Internal Revenue Service's (IRS) notices of deficiency were not time-barred. The IRS assessed deficiencies in income taxes as to appellants' taxable years 1983 and 1984, one year after it executed a settlement agreement with taxpayers. Taxpayers assert that the one-year statute of limitations was triggered when they signed the settlement...

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