IN RE JACKSON

No. 98-56014.

184 F.3d 1046 (1999)

In re Marion Dale JACKSON; Patricia L. Jackson, Debtors. California Franchise Tax Board, Appellant, v. Marion Dale Jackson; Patricia L. Jackson, Appellees.

United States Court of Appeals, Ninth Circuit.

Filed July 22, 1999.


Attorney(s) appearing for the Case

Gregory S. Price, Deputy Attorney General, San Diego, California, for the appellant.

James A. Hayes, Jr., Ashworth, Hayes & Moran, Laguna Niguel, California, for the appellees.

Before: PREGERSON, WIGGINS, and BRUNETTI, Circuit Judges.


BRUNETTI, Circuit Judge:

I. FACTS AND PROCEEDINGS BELOW

The facts of this case are not in dispute. The Internal Revenue Service ("IRS") reassessed the Jacksons' federal income tax liabilities for the 1982, 1983, and 1989 tax years, but the Jacksons did not notify the California Franchise Tax Board ("Board") of the federal reassessments as they were required to do under California law. The Jacksons filed for bankruptcy in 1996 and the Board filed a proof...

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