United States v. Jerome L. Doff

972 F.2d 1344 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNITED STATES of America, Plaintiff-Appellee, v. Jerome L. DOFF, Defendant-Appellant. No. 89-55324. United States Court of Appeals, Ninth Circuit. Submitted July 27, 1992. * Decided Aug. 3, 1992. As Amended on Denial of Rehearing Sept. 4, 1992. Before EUGENE A. WRIGHT, FARRIS and BEEZER, Circuit Judges. 1 MEMORANDUM ** 2 In 1960 and 1961, the United States disallowed some of Jerome Doff's tax deductions. The United States subsequently sought payment of those taxes plus interest and penalties. In 1978, the tax court entered a decision pursuant to a written stipulation between Doff and the government. He then paid approximately $109,000 in taxes, but nothing in interest. In 1984, the government filed a complaint against Doff to reduce his tax assessments to judgment under 26 U.S.C. § 7401 . The government alleged that he still owed $216,411.37 in interest. 3 Because the government failed to effect service…