USCA1 Opinion

      [NOT FOR PUBLICATION--NOT TO BE CITED AS PRECEDENT]

                 United States Court of Appeals

                     For the First Circuit











No. 98-1490



                       JUNE MADELYN WHITE,



                      Plaintiff, Appellant,



                                v.



                          UNITED STATES,



                       Defendant, Appellee.







           APPEAL FROM THE UNITED STATES DISTRICT COURT



                FOR THE DISTRICT OF MASSACHUSETTS



           [Hon. Joseph L. Tauro, U.S. District Judge]







                              Before



                     Torruella, Chief Judge,

                Campbell, Senior Circuit Judge,

                   and Lipez, Circuit Judge.

                                

                                





     June M. White on brief pro se.

     Loretta C. Argrett, Assistant Attorney General, Gary D. Grayand Edward T. Perelmuter, Attorneys, Tax Division, Department of

Justice and Donald K. Stern, United States Attorney, on brief for

appellee.











April 7, 1999







                                

                                



     Per Curiam.  After careful consideration of the briefs and

record below, we affirm the judgment of the district court.  The

appellant argues that the district court should have ruled on the

issue of the timing of the notice of the 1985 tax deficiency. She

effectively seeks belated review of the 1992 Tax Court decision. 

The district court had no power to review the Tax Court's decision. 

26 U.S.C.  7482, 7483. 

          The appellant sought, and the government agreed to, a

redetermination of her 1985 income tax liability.  The appellant

agreed to be bound by that redetermination.  She fails to show that

the agreement was not binding.  Her belated decision, on the basis

of new evidence, that it would have been better to litigate the

notice issue, an issue which could not have been litigated in

district court, cannot free her from her obligations under the

agreement.  Mathewson Corporation v. Allied Marine Industries, Inc. 

827 F.2d 850, 856 (1st Cir. 1987); Ross-Simons of Warwick, Inc. v.

Baccarat, Inc., 102 F.3d 12, 17, (1st Cir. 1996)  .

           Affirmed.  Loc. R. 27.1.