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ABBOTT v. U.S. I.R.S.

Nos. 03-71908, 03-71919.

399 F.3d 1083 (2005)

Lucille ABBOTT; Ann Sexton; Lucille Abbott Sexton; Ann Sexton Peterson, Petitioners-Appellants, v. UNITED STATES INTERNAL REVENUE SERVICE, Respondent-Appellee, Ann Sexton Peterson, Executor, Estate of Lucille Abbott Sexton, Deceased, Petitioner-Appellant, v. Commissioner of Internal Opinion Revenue, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed March 1, 2005.

Attorney(s) appearing for the Case

Robert P. Sticht, Los Angeles, California, for the petitioners-appellants.

Francesca U. Tamami, United States Justice Department, Washington, D.C., for the respondent-appellee.

Before: NOONAN, THOMPSON, and HAWKINS, Circuit Judges.

NOONAN, Circuit Judge.

The taxpayer, Ann Sexton Peterson, executor of the estate of Lucille Abbott Sexton, appeals the Tax Court's denial of her motion to vacate its decisions of January 23, 2001. These decisions were based on stipulations by the parties. The lawyer for the taxpayer was employed as a consultant by the Internal Revenue Service during the period he represented the estate. Alleging a breach of legal ethics such that the estate had not been properly represented...

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