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CHIMBLO v. C.I.R.

Docket Nos. 98-4306, 98-4307.

177 F.3d 119 (1999)

Josephine CHIMBLO, Estate of Anthony J. Chimblo, Deceased, Rosalie Monahan, Executrix, and Catherine Chimblo, Estate of Gus Chimblo, Deceased, Catherine Chimblo, Executrix, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided May 17, 1999.

Attorney(s) appearing for the Case

Tobias Weiss, Stamford, CT, for Petitioners-Appellants.

John A. Nolet, Tax Division, Department of Justice, Washington, DC (Loretta C. Argrett, Assistant Attorney General, William S. Estabrook, Attorney, Tax Division, Charles S. Casazza, Appellate Deputy, United States Tax Court, Stuart L. Brown, Office of Chief Counsel, Internal Revenue Service, of counsel), for Respondent-Appellee.

Before: WALKER and CABRANES, Circuit Judges, and TSOUCALAS, Judge.

JOHN M. WALKER, Jr., Circuit Judge:

Petitioners appeal from the decisions of the United States Tax Court (Dinan, J.), rejecting their contention that they were not properly notified of earlier partnership proceedings which led to the determination of petitioners' tax deficiencies, and finding petitioners liable for additions to tax stemming from petitioners' negligence in substantially underpaying their taxes. We affirm.

I. BACKGROUND

A....

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