Allan S. Haley Roberta J. Rowlands v. Commissioner, Internal Revenue Service
Opinion
Opinion
5 F.3d 536 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Allan S. HALEY; Roberta J. Rowlands, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 91-70739. United States Court of Appeals, Ninth Circuit. Submitted Aug. 11, 1993. * Decided Aug. 16, 1993. Appeal from a Decision of the United States Tax Court. USTC AFFIRMED IN PART AND DISMISSED IN PART Before: SNEED, POOLE, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Allan Haley and Roberta Rowlands appeal the Tax Court's denial of their petition to redetermine an income tax deficiency for the 1975 tax year and the Tax Court's denial of their motion for leave to file out of time a motion to vacate or revise the Tax Court's denial of the petition. We affirm in part and dismiss in part. 3 * The Tax Court entered an order denying the taxpayers' petition for redetermination on July 19, 1990. Taxpayers filed a notice of appeal on November 27, 1991. "Review of a decision of the Tax Court…