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

979 F.2d 141 69 A.F.T.R.2d 92 -1480, 70 A.F.T.R.2d 92 -6012, 92-1 USTC P 60,099 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, Defendant-Appellee. 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 Memorandum Withdrawn May 10, 1992. Submission Withdrawn and Resubmitted May 1, 1992. Decided May 11, 1992. As Amended Oct. 23, 1992. As Amended on Denial of Rehearing and Rehearing En Banc Dec. 8, 1992. Roy B. Thompson, Roy B. Thompson, PC, Portland, Or., for plaintiffs-appellants. Shirley D. Peterson, Acting Asst. Atty. Gen., U.S. Dept. of Justice, Washington, D.C., for defendants-appellees. Appeal from the United States District Court for the District of Oregon. ORDER AND AMENDED OPINION Before WRIGHT,…