Jack H. Satterfield Myrle Satterfield v. United States Internal Revenue Service, Department of the Treasury of the U.S.

76 F.3d 388 77 A.F.T.R.2d 96 -635 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Jack H. SATTERFIELD; Myrle Satterfield, Plaintiffs-Appellants, v. UNITED STATES INTERNAL REVENUE SERVICE, DEPARTMENT OF the TREASURY OF the U.S., Defendant-Appellee. No. 94-36240. United States Court of Appeals, Ninth Circuit. Submitted Jan. 23, 1996. * Decided Jan. 26, 1996. Before: BROWNING, WRIGHT, and CANBY, Circuit Judges. 1 H. Jack and Myrle Satterfield appeal the district court's adverse judgment in their suit challenging an IRS lien against their property. We conclude the district court lacked jurisdiction, and vacate the judgment below. I. 2 From 1976 through 1978, the Satterfields used a tax shelter called a "silver straddle." IRS appeals officer Cal Crandall told the Satterfields' attorney, Lowell Hawkes, that the IRS would recharacterize the 1976-77 straddle gain as a short term gain and disallow the 1977-78 straddle loss, which would increase the Satterfields' 1977 taxable income…