United States Ninth Circuit

In a challenge to an IRS deficiency notice in Tax Court, the deficiency judgment is affirmed, where the six-year statute of limitations applied to the deficiency notice because the taxpayers omitted gross income from the returns at issue.

Appellate Information

• Argued 01/12/2009
• Decided 03/31/2009
• Published 03/31/2009

Judges

• FARRIS, Senior Circuit Judge:, Before:  J. CLIFFORD WALLACE, JEROME FARRIS and M. MARGARET McKEOWN, Circuit Judges.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• John M. Youngquist, San Francisco, CA, for petitioners Burton Benson and Elizabeth Benson.


• For Appellees:
  
• Ellen Page DeSole, Department of Justice, Tax Division, Washington, D.C.;   Michael J. Huangs, Department of Justice, Tax Division, Washington, D.C.;   Nathan J. Hochman, Assistant Attorney General, for respondent Commissioner of Internal Revenue.