United States Ninth Circuit
Ulrich v. Comm'r. of Int'l. Rev., 08-70718
In an appeal from the tax court's decision denying taxpayers' appeal from an IRS collection due process hearing, the order is affirmed where the taxpayers' waiver of their right to receive a notice of deficiency did not require acceptance by the IRS to become effective, and the taxpayers had waived their pre-collection right to contest liability.
Appellate Information
- Decided 11/03/2009
- Published 11/03/2009
Judges
- PER CURIAM., Before: MARY M. SCHROEDER, STEPHEN REINHARDT and CARLOS T. BEA, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Joe Alfred Izen, Jr., Bellaire, TX, for the petitioners.
- For Appellees:
- Nathan J. Hochman, Assistant Attorney General, and Steven W. Parks and Ivan C. Dale, Attorneys, Tax Division, Department of Justice, Washington, DC, for the respondent.