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PCCE, INC. v. U.S.

No. 97-55408.

159 F.3d 425 (1998)

PCCE, INC., Plaintiff-Appellant, v. UNITED STATES of America; Internal Revenue Service, Defendants-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided October 27, 1998.

Attorney(s) appearing for the Case

Michael C. Cohen, De Castro, West & Chodorow, Los Angeles, CA, for plaintiff-appellant PCCE, Inc.

Curtis C. Pett, Tax Division, United States Department of Justice, Washington, DC, for defendant-appellee.

Before: BROWNING, PREGERSON, and HAWKINS, Circuit Judges.

PREGERSON, Circuit Judge:

Plaintiff-Appellant PCCE ("taxpayer"1) challenges the government's tax and interest assessments for tax years 1974 and 1978, as well as its tax liens. The Tax Court entered a stipulated judgment in which the parties agreed as to the amount taxpayer owed. The district court determined the assessments and liens to be valid.

On appeal taxpayer does not argue that the government assessed these tax and interest...

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