Henry Barragan Carol Barragan v. Commissioner Internal Revenue Service

69 F.3d 543 76 A.F.T.R.2d 95 -7425, 95-2 USTC P 50,624 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Henry BARRAGAN; Carol Barragan, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70136. United States Court of Appeals, Ninth Circuit. Argued and Submitted Sept. 11, 1995. Decided Nov. 2, 1995. 1 Before: T.G. NELSON and KLEINFELD, Circuit Judges, and LEGGE, * District Judge. 2 MEMORANDUM ** 3 * Henry and Carol Barragan appeal the United States Tax Court's decision in favor of the Commissioner of Internal Revenue ("CIR" or "the Commissioner") in their petition under the Internal Revenue Code ("I.R.C."), 26 U.S.C. Secs. 6213 , 6214 and 7442, for redetermination of income tax deficiencies and additions for tax years 1983 through 1987. After conducting a trial, the tax court deemed reasonable the CIR's method of determining deficiencies and held Henry Barragan liable for additions to tax due to fraud. We affirm the tax court's…