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HILLMAN v. INTERNAL REVENUE SERVICE

No. 00-1915

263 F.3d 338 (2001)

David H. Hillman; Suzanne Hillman, Petitioners-Appellees, v. Internal Revenue Service, Respondent-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: April 17, 2001

Attorney(s) appearing for the Case

Kenneth L. Greene, Tax Division, United States Department of Justice, Washington, D.C., for Appellant.

Stefan F. Tucker, Venable, Baetjer, Howard & Civiletti, L.L.P., Washington, D.C., for Appellees.

Paula M. Junghans, Acting Assistant Attorney General, Howard T. Perelmuter, Tax Division, United States Department of Justice, Washington, D.C., for Appellant.

David E. Sellinger, Susan Edlavitch, Damon W.D. Wright, Venable, Baetjer, Howard & Civiletti, L.L.P., Washington, D.C., for Appellees.

Before: WILKINS and WILLIAMS, Circuit Judges, and HAMILTON, Senior Circuit Judge.

HAMILTON, Senior Circuit Judge

In mid-July 1997, David and Suzanne Hillman (the Hillmans) received written notice from the Commissioner of the United States Internal Revenue Service (the Commissioner) that a deficiency existed in the amount of federal income taxes they had paid for taxable years 1993 and 1994. According to the notice, the Hillmans still owed the government $294,556.00 in federal income taxes for taxable year 1993 and $309,696.00 in federal income...

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