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FARGO v. C.I.R.

No. 04-72190.

447 F.3d 706 (2006)

Charles G. FARGO; Elizabeth A. Fargo, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed May 8, 2006.

Attorney(s) appearing for the Case

Dennis N. Brager, Law Offices of Dennis N. Brager, Los Angeles, CA, for the appellants.

Randolph L. Hutter, Tax Division, United States Department of Justice, Washington, DC, for the appellee.

Terri A. Merriam, Pearson Merriam, Seattle, WA, for the amici.

Before BEEZER, HALL, and WARDLAW, Circuit Judges.

HALL, Senior Circuit Judge.

Charles and Elizabeth Fargo (Taxpayers) appeal the decision of the Tax Court holding that the Commissioner of Internal Revenue did not abuse his discretion by rejecting their offer to pay $7,500 in compromise of the approximately $104,000 interest owed on their 1983 and 1984 federal income tax liabilities. We affirm.

I. Facts

More than twenty years ago, Taxpayers bought interests in two partnerships: the Jackson &...

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