Nicholas T. Scott v. United States of America, Nicholas T. Scott, Plaintiff-Appellee/cross-Appellant v. United States of America Irs, Director, Defendants-Appellants/cross-Appellees

70 F.3d 120 76 A.F.T.R.2d 95 -6886, 95-2 USTC P 50,557 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Nicholas T. SCOTT, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant. Nicholas T. SCOTT, Plaintiff-Appellee/Cross-Appellant, v. UNITED STATES of America; IRS, Director, Defendants-Appellants/Cross-Appellees. Nos. 94-15321, 94-15323. United States Court of Appeals, Ninth Circuit. Argued and Submitted June 5, 1995. Decided Oct. 5, 1995. 1 Before: FLETCHER, WIGGINS and FERNANDEZ, Circuit Judges 2 MEMORANDUM * BACKGROUND 3 In the early 1980s, Nicholas Scott began to experience severe difficulties resulting from his alcohol abuse, including multiple citations for driving under the influence of alcohol and the loss of his job. He turned over power of attorney for his financial affairs to his father. In 1984, pursuant to the power of attorney, Mr. Scott's father made a number of federal tax deposits on Mr. Scott's behalf. Then, after Mr. Scott revoked the…