Praxiteles, Inc. Sheldon M. Sisson, a Person Other Than the Tax Matters Person v. Commissioner Internal Revenue Service

70 F.3d 1279 76 A.F.T.R.2d 95 -7797, 96-1 USTC P 50,049 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. PRAXITELES, INC.; Sheldon M. Sisson, A Person Other Than The Tax Matters Person, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70137. United States Court of Appeals, Ninth Circuit. Submitted Nov. 17, 1995. * Decided Dec. 5, 1995. 1 Before: FLETCHER, CANBY and HAWKINS, Circuit Judges 2 MEMORANDUM ** 3 Sheldon M. Sisson, a person other than the tax matters person, brought this action on behalf of Praxiteles, Inc. Sisson was a shareholder of Praxiteles, a now-dissolved California subchapter-S corporation. Sisson appeals the decision of the Tax Court, which upheld the Internal Revenue Service's Notice of Final S Corporation Administrative Adjustment. This court has jurisdiction pursuant to the IRC Secs. 6226(b) & 6244. We affirm the decision of the Tax Court. 4 We will not repeat the facts here because the parties are…