Ulrich

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

SHERYL L. ULRICH; JUDSON L. 

ULRICH,

No. 08-70718 Petitioners, v.  Tax Ct. No. 7738-06L

COMMISSIONER OF INTERNAL

OPINION

REVENUE,

Respondent.  Appeal from a Decision of the United States Tax Court

Argued and Submitted September 17, 2009—San Francisco, California

Filed November 3, 2009

Before: Mary M. Schroeder, Stephen Reinhardt and Carlos T. Bea, Circuit Judges.

Per Curiam Opinion

14809 ULRICH v. CIR 14811

COUNSEL

Joe Alfred Izen, Jr., Bellaire, Texas, for the petitioners.

Nathan J. Hochman, Assistant Attorney General, and Steven W. Parks and Ivan C. Dale, Attorneys, Tax Division, Depart- ment of Justice, Washington, D.C., for the respondent.

OPINION

PER CURIAM:

Judson and Sheryl Ulrich appeal a decision of the United States Tax Court denying their appeal from a Collection Due Process Hearing in which the Internal Revenue Service (IRS) Appeals Office determined that the IRS could proceed with collection of the Ulrichs’ 1999, 2000, and 2001 taxes. We have jurisdiction pursuant to 26 U.S.C. § 7482(a)(1). We affirm. 14812 …