Richard F. Broderick Margaret E. Broderick v. Commissioner Internal Revenue Service

29 F.3d 630 74 A.F.T.R.2d 94 -5550 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Richard F. BRODERICK; Margaret E. Broderick, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 93-70761. United States Court of Appeals, Ninth Circuit. Submitted July 18, 1994. * Decided July 25, 1994. Before: FARRIS, KOZINSKI, and NOONAN, Circuit Judges. 1 MEMORANDUM ** 2 Richard and Margaret Broderick appeal pro se the tax court's order granting the Internal Revenue Service's ("IRS") motion for entry of judgment based upon the parties purported settlement agreement in the Brodericks' action for redetermination of a tax deficiency for 1988. We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 . We reverse and remand. 3 * Background 4 The IRS issued a notice of deficiency on July 3, 1991 for the Brodericks' 1988 federal income taxes. The Brodericks filed a petition on October 7, 1991 contesting the IRS's deficiency determination. On March 31, 1992,…