Corinne E. Andrews v. Commissioner of Internal Revenue

15 F.3d 1082 73 A.F.T.R.2d 94 -660 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Corinne E. ANDREWS, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 93-70428. United States Court of Appeals, Ninth Circuit. Argued and Submitted Dec. 6, 1993. Decided Dec. 22, 1993. As Amended Jan. 26, 1994. Before: HUG, SCHROEDER, and FERGUSON, Circuit Judges. 1 MEMORANDUM * 2 The appellant, Corinne E. Andrews, filed joint returns with her husband for tax years 1980, 1981, and 1982. Those returns reflected improper deductions, and the Commissioner of Internal Revenue later issued two assessments, one covering the years 1980 and 1981 and one covering 1982. Appellant's liability on the two assessments was tried before two different tax court judges after she petitioned for innocent spouse relief pursuant to the provisions of 26 U.S.C. Sec. 6013 (e) (1988). The case before this court, which covers the assessment for the years 1980 and 1981, was tried first.…