Davis v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT RALPH H. DAVIS; EVELYN DAVIS,  Personal Representative, No. 03-72240 Petitioners-Appellants, v.  IRS No. 210-02 COMMISSIONER OF INTERNAL OPINION REVENUE, Respondent-Appellee.  Appeal from a Decision of the United States Tax Court Submitted December 10, 2004* San Francisco, California Filed January 24, 2005 Before: Jerome Farris, Dorothy W. Nelson, and Ronald M. Gould, Circuit Judges. Opinion by Judge Gould *This panel unanimously finds this case suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2).…