Allan S. Haley Roberta J. Rowlands v. United States Internal Revenue Service

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NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel.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, Plaintiffs-Appellants, v. UNITED STATES INTERNAL REVENUE SERVICE, Defendant-Appellee. No. 92-16391. United States Court of Appeals, Ninth Circuit. Submitted Aug. 11, 1993. * Decided Aug. 16, 1993. Appeal from the United States District Court for the Eastern District of California; William B. Shubb, District Judge, Presiding. E.D.Cal., 805 F.Supp. 834 . AFFIRMED. Before: SNEED, POOLE, and TROTT, Circuit Judges. 1 MEMORANDUM ** 2 Allan Haley and Roberta Rowlands ("taxpayers") appeal the district court's grant of summary judgment in favor of the Commissioner of Internal Revenue in their action under 26 U.S.C. Sec. 6213 (a) (1988) to enjoin a tax deficiency assessment. We have jurisdiction pursuant to 28 U.S.C. Sec. 1291 , and we affirm. 3 Taxpayers argue a deficiency assessment on December 12, 1990, of $98,550.44 in taxes due for the tax year 1975 was improper, because the Tax…