United States First Circuit

In an action by the government against defendant-taxpayers to reduce to judgment federal income tax liabilities, dismissal of defendants' claims of improper notice because their attorney supposedly failed to receive notice of tax liens and that the IRS improperly failed to consider the wife's innocent spouse defense, is affirmed as the claims are foreclosed by res judicata and are without merit.

Appellate Information

• Decided 12/14/2009
• Published 12/14/2009

Judges

• TASHIMA, Senior Circuit Judge., Before BOUDIN and HOWARD, Circuit Judges, and TASHIMA, Senior Circuit Judge.

Court

• United States First Circuit

Counsel

• For Appellant:
  
• Timothy J. Burke, for appellants.


• For Appellees:
  
• John Schumann, Tax Division, U.S. Department of Justice, with whom John A. DiCicco and Bridget M. Rowan were on briefs, for appellees.