Brian Holland, Diedre Holland v. Commissioner of Internal Revenue

992 F.2d 1219 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Brian HOLLAND, Diedre Holland, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 92-70086. United States Court of Appeals, Ninth Circuit. Argued and Submitted April 16, 1993. Decided April 30, 1993. Before GOODWIN, HUG and FLETCHER, Circuit Judges. 1 MEMORANDUM * 2 Petitioners-appellants Brian Holland and Diedre Holland ("petitioners") appeal the tax court's dismissal on jurisdictional grounds of their petition for redetermination of asserted federal income tax deficiencies. The tax court ruled that it had no jurisdiction to consider a petition filed almost two and one-half years after a notice of deficiency had been sent to petitioners' last known address, and granted the Commissioner's motion to dismiss. We have jurisdiction over petitioners' timely appeal pursuant to 26 U.S.C. § 7482 (a) (1988), and we affirm. 3 Petitioners' primary argument is that because they did…