Faramarz Fayeghi and Shelli Fayeghi,petitioners-Appellants v. Commissioner of Internal Revenue,respondent-Appellee

GRABER, Circuit Judge:

Petitioners Faramarz and Shelli Fayeghi filed a motion in the tax court to restrain collection of taxes. The tax court denied the motion, concluding that it lacked authority to restrain collection in the circumstances. The tax court’s conclusions of law and interpretation of the Internal Revenue Code are subject to de novo review. See Estate of Rapp v. Commissioner, 140 F.3d 1211, 1215 (9th Cir.1998). We affirm.

FACTS AND PROCEDURAL HISTORY

In October 1991, Petitioners filed a joint federal personal income tax return for 1990 in which they reported that they owed $107,771…