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KINDRED v. COMMISSIONER OF INTERNAL REVENUE

No. 05-1424, 05-1435.

454 F.3d 688 (2006)

David and Lynette KINDRED, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 20, 2006.

Attorney(s) appearing for the Case

Robert A. Jones (argued), Las Vegas, NV, for Petitioner-Appellant.

Sara Ann Ketchum (argued), Deborah K. Snyder, Andrea Tebbets, Department of Justice Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.

Before COFFEY, MANION, and KANNE, Circuit Judges.

COFFEY, Circuit Judge.

After their income tax return was reviewed, taxpayers David and Lynette Kindred (collectively the "taxpayers") were determined by the Internal Revenue Service ("IRS" or "the Service") to be deficient in their payments for the tax year 1999. The taxpayers were informed of this when they were sent a statutory notice of deficiency, which provided them the opportunity to challenge the IRS' determination in the United States Tax Court ("Tax Court...

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