MILLER v. C.I.R.

No. 00-71285.

310 F.3d 640 (2002)

Marjorie Cathey MILLER, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Submitted July 16, 2002.

Filed November 8, 2002.


Attorney(s) appearing for the Case

Charles H. Hammer, Spokane, Washington, for the petitioner-appellant.

Annette M. Wietecha, Department of Justice, Tax Division, Washington, DC, for the respondent-appellee.

Before: REAVLEY, TASHIMA, and RAWLINSON, Circuit Judges.


TASHIMA, Circuit Judge.

Marjorie Cathey Miller appeals a decision of the United States Tax Court, granting summary judgment in favor of the Commissioner of Internal Revenue. Miller contends that the tax court erred in concluding that she was not entitled to an abatement of interest on employment taxes under 26 U.S.C. § 6404(e). We affirm.

BACKGROUND

In 1984, 1985, and 1986, Miller operated a beauty salon in the State of Washington. Miller leased...

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