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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