Reiserer

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

KENNETH H. REISERER; REISERER & 

AGEE LLP, by Kenneth H. No. 05-35615 Reiserer, its successor in interest, Petitioners-Appellants,  D.C. No.

CV-04-00967-JCC

v.

OPINION

UNITED STATES OF AMERICA,

Respondent-Appellee.  Appeal from the United States District Court for the Western District of Washington John C. Coughenour, Chief District Judge, Presiding

Argued and Submitted December 6, 2006—Seattle, Washington

Filed March 20, 2007

Before: Betty B. Fletcher and M. Margaret McKeown, Circuit Judges, and William W Schwarzer,* District Judge.

Opinion by Judge Schwarzer

*The Honorable William W Schwarzer, Senior United States District Judge for the Northern District of California, sitting by designation.

3291 3294 REISERER v. UNITED STATES

COUNSEL

John M. Colvin, Chicoine & Hallett, P.S., Seattle, Washing- ton, for the appellants.

Gretchen M. Wolfinger, Tax Division, U.S. Department of Justice, Washington, D.C., for the appellee.

OPINION

SCHWARZER, District Judge:

The Estate of Kenneth Reiserer and the law firm Reiserer & Agee LLP (collectively, Reiserer) appeal the…