Jerome E. Kozlowski and Martha E. Kozlowski v. Commissioner Internal Revenue Service

70 F.3d 1279 76 A.F.T.R.2d 95 -7744, 96-1 USTC P 50,021 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jerome E. KOZLOWSKI; and Martha E. Kozlowski, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70337. United States Court of Appeals, Ninth Circuit. Argued and Submitted Nov. 13, 1995. Decided Nov. 28, 1995. 1 Before: SCHROEDER and ALARCON, Circuit Judges, and PANNER, * Senior District Judge 2 MEMORANDUM ** 3 Jerome E. Kozlowski and Martha E. Kozlowski (the "Kozlowskis") appeal from the order of the Tax Court granting partial summary judgment and ruling in favor of the Commissioner of Internal Revenue (the "Commissioner") in the Kozlowskis' petition contesting the Commissioner's imposition of additional interest and the imposition of a negligence penalty. We affirm both rulings. I. 4 In April 1986, the Commissioner determined a deficiency in the Kozlowskis' 1980 Federal income taxes. The deficiency resulted from the…