963 F.2d 1156w

69 A.F.T.R.2d 92-1331, 92-2 USTC P 50,381

Gordon E. POWELSON, personal representative of the estate of
Clydena M. Gross, Plaintiff-Appellant,
v.
UNITED STATES of America, acting By and Through its
SECRETARY OF the TREASURY; IRS, Defendants-Appellees.
Gordon E. POWELSON, an individual; Chicago Title Insurance
Company of Oregon, an Oregon corporation,
Plaintiffs-Appellants,
v.
UNITED STATES of America, acting By and Through its
SECRETARY OF the TREASURY and its Internal Revenue
Service, Defendants-Appellees.

Nos. 89-35736, 90-35005.

United States Court of Appeals,
Ninth Circuit.

Argued and Submitted Nov. 9, 1990.
Memorandum Filed Aug. 30, 1991.
Memorandum Withdrawn May 10, 1992.
Submission Withdrawn and Resubmitted
May 1, 1992.

Filed May 11, 1992.

NOTE: THE COURT HAS WITHDRAWN THIS OPINION