Conrad Keado v. United States of America, Conrad L. Keado and Linda W. Keado v. Commissioner of Internal Revenue

GOLDBERG, Circuit Judge:

The plaintiffs appeal from a federal district court decision denying their request for an injunction barring collection of deficiencies asserted by the Internal Revenue Service. They also appeal from a Tax Court decision dismissing their petition on the ground that it was not timely filed. Finding both decisions correct, we affirm.

I. BACKGROUND

The Internal Revenue Service (“IRS”) audited the 1980 and 1981 tax returns filed by Conrad L. Keado and his wife, Linda W. Keado (the “Taxpayers”), and determined deficiencies 1 in their reported tax liabilities.

The Internal…