Wesley H. Hillendahl, Marilyn G. Hillendahl v. Commissioner of Internal Revenue

976 F.2d 737 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Wesley H. HILLENDAHL, Marilyn G. Hillendahl, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 91-70405. United States Court of Appeals, Ninth Circuit. Argued and Submitted July 8, 1992. Decided Sept. 21, 1992. Before FARRIS, WIGGINS and FERNANDEZ, Circuit Judges. 1 MEMORANDUM * OVERVIEW 2 Appellants, Wesley and Marilyn Hillendahl, appeal the tax court's decision imposing penalties under Internal Revenue Code section 6659 and 6621 for underpayment of taxes. The tax court found the Hillendahls liable for additional taxes under I.R.C. section 6659 because they underpaid their income taxes as a result of valuation overstatements. 1 Further, the tax court held the appellants liable for an increased rate of interest which is applicable under I.R.C. section 6621(c) 2 to tax-motivated transactions. This court has jurisdiction over the timely appeal pursuant to I.R.C. section 7482, and…