United States v. Stanley Burrell

MEMORANDUM **

Defendants Stanley and Stephanie Burrell appeal from a judgment in favor of the United States for 1996 and 1997 income taxes. On de novo review of this summary judgment, Baccei v. United States, 632 F.3d 1140, 1144 (9th Cir.2011), we affirm.

Like the district court, we reject Defendants’ argument that the government was equitably estopped from collecting the 1996 and 1997 taxes. Defendants argue for estoppel based on the government’s failure to include those taxes in a proof of claim in their bankruptcy proceeding, along with a stipulation entered into in 2000 stating that “the…