William Alberts Virginia C. Alberts v. Commissioner of Internal Revenue Service

8 F.3d 25 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. William ALBERTS; Virginia C. Alberts, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent-Appellee. Nos. 91-70239 to 91-70247 and 91-70332. United States Court of Appeals, Ninth Circuit. Argued and Submitted June 8, 1993. Submission Withdrawn July 30, 1993. Resubmitted Sept. 27, 1993. Decided Sept. 30, 1993. Before: FLETCHER, POOLE, and THOMPSON, Circuit Judges. 1 MEMORANDUM * 2 William and Virginia Alberts and other taxpayers (collectively "taxpayers") appeal the tax court's decision granting the Commissioner of the Internal Revenue Service's motion for entry of decision in the taxpayers' action seeking a redetermination of their income tax deficiencies. We have jurisdiction under 28 U.S.C. § 7482 (a), and we affirm as to all taxpayers except the Johnsons, No. 91-70243, and the Nobles, No. 91-70332. Pursuant to the Commissioner's request, we remand Johnson, No. 91-70243, for…