Jon M. Putnam, Helen M. Putnam, Nuclear Services, Inc. v. Commissioner Internal Revenue Service

72 F.3d 135 76 A.F.T.R.2d 95 -8010 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jon M. PUTNAM, Helen M. Putnam, Nuclear Services, Inc., Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 94-70339. United States Court of Appeals, Ninth Circuit. Submitted Dec. 5, 1995. * Decided Dec. 8, 1995. Before: PREGERSON, BRUNETTI, and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 2 Appellants, Jon M. and Helen M. Putnam, appeal the decision of the Tax Court assessing a deficiency against them in the amount of $12,335.00 for the tax year 1984 and $13,240.00 for the tax year 1985. We have jurisdiction pursuant to 26 U.S.C. Sec. 7482 (a)(1) and affirm the Tax Court's decision. 3 The stipulations filed by the parties on January 28, 1993 and August 9, 1993 effectively removed from consideration all issues except the applicability of the six-year statute of limitations to the Commissioner's deficiency assessment pursuant to 26 U.S.C. Sec. 6501…