Gordon E. Powelson, Personal Representative of the Estate of Clydena M. Gross v. United States of America, Acting by and Through Its Secretary of the Treasury Irs, Gordon E. Powelson, an Individual Chicago Title Insurance Company of Oregon, an Oregon Corporation v. United States of America, Acting by and Through Its Secretary of the Treasury and Its Internal Revenue Service

963 F.2d 1156w 69 A.F.T.R.2d 92 -1331, 92-2 USTC P 50,381 Gordon E. POWELSON, personal representative of the estate of Clydena M. Gross, Plaintiff-Appellant, v. UNITED STATES of America, acting By and Through its SECRETARY OF the TREASURY; IRS, Defendants-Appellees. Gordon E. POWELSON, an individual; Chicago Title Insurance Company of Oregon, an Oregon corporation, Plaintiffs-Appellants, v. UNITED STATES of America, acting By and Through its SECRETARY OF the TREASURY and its Internal Revenue Service, Defendants-Appellees. Nos. 89-35736, 90-35005. United States Court of Appeals, Ninth Circuit. Argued and Submitted Nov. 9, 1990. Memorandum Filed Aug. 30, 1991. Memorandum Withdrawn May 10, 1992. Submission Withdrawn and Resubmitted May 1, 1992. Filed May 11, 1992. NOTE: THE COURT HAS WITHDRAWN THIS OPINION