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FAYEGHI v. C.I.R.

No. 98-71375.

211 F.3d 504 (2000)

Faramarz FAYEGHI and Shelli Fayeghi, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed May 3, 2000.

Attorney(s) appearing for the Case

Joel G. Selik, Solana Beach, California; Douglas M. Edwards, Edwards & Winterton, Las Vegas, Nevada, for the petitioners-appellants.

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

Before: TASHIMA and GRABER, Circuit Judges, and STOTLER, District Judge.

GRABER, Circuit Judge:

Petitioners Faramarz and Shelli Fayeghi filed a motion in the tax court to restrain collection of taxes. The tax court denied the motion, concluding that it lacked authority to restrain collection in the circumstances. The tax court's conclusions of law and interpretation of the Internal Revenue Code are subject to de novo review. See Estate of Rapp v. Commissioner, 140 F.3d 1211, 1215 (9th Cir. 1998...

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