Gordon E. Powelson, Personal Representative of the Estate Ofclydena M. Gross, Plaintiff-appellant, v. United States of America, Acting by and Through Itssecretary of the Treasury; Irs, Defendants-appellees.gordon E. Powelson, an Individual; Chicago Title Insurancecompany of Oregon, an Oregon Corporation,plaintiffs-appellants, v. United States of America, Acting by and Through Itssecretary of the Treasury and Its Internal Revenueservice, Defendants-appellees, 963 F.2d 1156 (9th Cir. 1992)