STRANGE v. C.I.R.

No. 00-70749.

270 F.3d 786 (2001)

Charles E. STRANGE; Sherrie R. Strange, Petitioners-Appellants, v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed November 8, 2001.


Attorney(s) appearing for the Case

L. Robert LeGoy, Jr. and Kurt O. Hunsberger, Walther, Key, Maupin, Oats, Cox & LeGoy, Reno, Nevada, for the petitioners-appellants.

David English Carmack and Tamara W. Ashford, Tax Division, United States Department of Justice, Washington, D.C., for the respondent-appellee.

Before: Joseph T. Sneed, Stephen S. Trott, and Richard C. Tallman, Circuit Judges.


Argued and Submitted October 16, 2001 — San Francisco, California.

OPINION

SNEED, Circuit Judge:

Charles and Sherrie Strange ("Taxpayers") appeal the Tax Court's assessment of federal income tax deficiencies. The Tax Court found that Taxpayers, in calculating adjusted gross income, had improperly deducted nonresident state income taxes on net oil and gas royalties. We have jurisdiction under Internal Revenue Code ("Code" or "I.R.C.") §...

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