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BROOKES v. C.I.R.

No. 97-70363.

163 F.3d 1124 (1998)

Lawrence V. BROOKES and Katherine T. Brookes, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided December 22, 1998.

Attorney(s) appearing for the Case

Lawrence V. Brookes, pro se, San Francisco, California, for the petitioners-appellants.

Randolph L. Hutter, United States Department of Justice, Tax Division, Washington, D.C., for the respondent-appellee.

Before: Cynthia Holcomb Hall, Diarmuid F. O'Scannlain, and Harlington Wood, Jr., Circuit Judges.

WOOD, Circuit Judge:

Lawrence V. Brookes and Katherine T. Brookes ("Taxpayers") received a notice of deficiency issued by the Commissioner of Internal Revenue ("Commissioner"). Taxpayers petitioned the Tax Court for a redetermination of the notice of deficiency which was based on their personal income tax returns. In addition to challenging the notice, Taxpayers' petition included counts concerning income tax adjustments which had been determined at a prior partnership...

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