United States Ninth Circuit
Fargo v. Comm'r of Internal Revenue, 04-72190
A tax court decision holding that the Commissioner of Internal Revenue did not abuse his discretion by rejecting taxpayers' offer to pay $7,500 in compromise of approximately $104,000 interest owed on their 1983-1984 federal income tax liabilities is affirmed over claims of error regarding economic hardship and exceptional circumstances.
Appellate Information
- Argued 12/05/2005
- Decided 05/08/2006
- Published 05/08/2006
Judges
- HALL, Senior Circuit Judge., Before BEEZER, HALL, and WARDLAW, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Dennis N. Brager, Law Offices of Dennis N. Brager, Los Angeles, CA, for the appellants., Terri A. Merriam, Pearson Merriam, Seattle, WA, for the amici.
- For Appellees:
- Randolph L. Hutter, Tax Division, United States Department of Justice, Washington, DC, for the appellee.