Seaview Trading, LLC, AGK Inve v. CIR
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March 10, 2023
Full 9th Circ. Sides With IRS In Partnership's $35.5M Loss Row
The IRS timely disallowed a partnership's $35.5 million loss as the partnership's failure to strictly comply with filing rules meant the agency's readjustment deadline didn't pass, the full Ninth Circuit ruled Friday, overruling a three-judge panel.
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December 13, 2022
9th Circ. Probes Tax Filings' Validity In $35M Partnership Row
A Ninth Circuit judge on Tuesday questioned a partnership's arguments that it properly filed its tax returns in a dispute involving a $35.5 million tax shelter-related deduction, saying the partnership relied on IRS guidance lacking the force of law to make its case.
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November 14, 2022
Full 9th Circ. To Review IRS Loss In $35.5M Partnership Row
The full Ninth Circuit will revisit a panel decision that reversed the U.S. Tax Court in allowing a partnership to claim a $35.5 million tax-shelter-related deduction because the IRS disallowed the claim too late.
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July 12, 2022
9th Circ. Urged To Rethink IRS Loss In $35.5M Partnership Row
The full Ninth Circuit should review a panel ruling that wrongly permitted a partnership to claim a $35.5 million tax shelter-related deduction, the U.S. government argued, saying the appeals court incorrectly concluded that the IRS disallowed the claim too late.
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May 11, 2022
9th Circ. Reverses IRS Win In $35.5M Partnership Tax Fight
A split Ninth Circuit panel reversed a U.S. Tax Court decision Wednesday and vacated a $35.5 million tax adjustment the Internal Revenue Service applied to a California-based partnership, ruling the agency's determination was barred by the statute of limitations.
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March 05, 2021
IRS' $35.5M Loss Adjustment Not Time-Barred, 9th Circ. Told
A partnership's failure to file a tax return for 2001 enabled the IRS to disallow a $35.5 million loss deduction the business claimed for that year roughly a decade later, the U.S. government told the Ninth Circuit on Friday.
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January 11, 2021
IRS' Statute Of Limitations Interpretation Is Harmful, 9th Circ. Told
The IRS' argument that only narrow circumstances start its time limit for making tax adjustments in a $35.5 million partnership deduction dispute may unduly harm lower-income taxpayers, a taxpayer advocacy group told the Ninth Circuit on Monday.
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January 05, 2021
$35.5M IRS Loss Adjustment Too Late, 9th Circ. Told
The IRS shouldn't have disallowed a partnership's $35.5 million loss deduction because the statute of limitations on its liability had expired, the partnership told the Ninth Circuit, urging it to reverse a U.S. Tax Court decision.