The Ninth Circuit Court of Appeals today released an opinion in CIR v. POLONE, No. 04-72672, a tax appeal. The panel consisted of Jerome Farris and Sidney R. Thomas, Circuit Judges, and George Schiavelli, District Judge.

THOMAS, Circuit Judge:
This appeal presents the question of whether payments received after the effective date of amendments to 26 U.S.C. . . .

The Ninth Circuit Court of Appeals today released an opinion in FARGO v. COMMISSIONER OF INTERNAL REVENUE, No. 04-72190, a tax appeal. The panel consisted of Robert R. Beezer, Cynthia Holcomb Hall, and Kim McLane Wardlaw, Circuit Judges.

HALL, Senior Circuit Judge:
Charles and Elizabeth Fargo (Taxpayers) appeal the decision of the Tax Court holding that the Commissioner of Internal Revenue did not abuse his discretion by rejecting their offer to pay $7,500 in compromise of the approximately $104,000 interest owed on their 1983 and 1984 federal income tax liabilities. We affirm. I. Facts More than twenty years ago, Taxpayers bought interests in two partnerships: the Jackson & Associates Partnership (Jackson), and the Smith & Asher Associates Partnership (Smith & . . .