Roger Chantel Darlene Chantel v. Commissioner of Internal Revenue

97 F.3d 1458 78 A.F.T.R.2d 96 -6566, 97-1 USTC P 50,137 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Roger CHANTEL; Darlene Chantel, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 96-71039. United States Court of Appeals, Ninth Circuit. Submitted Sept. 10, 1996. * Decided Sept. 12, 1996. Before: FLETCHER, BRUNETTI, and JOHN T. NOONAN, Jr., Circuit Judges. 1 MEMORANDUM ** 2 Taxpayers Roger and Darlene Chantel appeal pro se the Tax Court's decision holding that there was a deficiency in the their federal income tax for the taxable year 1986, and imposing an addition to tax. The Taxpayers contend that their 1986 tax return was timely filed in March 1987, and that the Commissioner of Internal Revenue's notice of deficiency issued in January 1995, was not timely filed within the three-year statute of limitations pursuant to 26 U.S.C. § 6501 (a). The Taxpayers claim that the Internal Revenue Service altered the filing date on the 1986…