United States Seventh Circuit

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Am. Boat Co., LLC. v. US, 09-1109

In a tax case where the IRS issued a Notice of Final Partnership Administrative Adjustment based on its determination that the defendants implemented an illegal tax shelter and misstated certain information on its tax documents resulting in significant tax underpayments, district court did not err in finding that defendant had reasonable cause for its tax position, and, consequently, that it was not subject to the accuracy-related penalty in 26 U.S.C. section 6662.

Appellate Information

  • Argued 05/28/2009
  • Decided 10/01/2009
  • Published 10/01/2009


  • KANNE, Circuit Judge., Before BAUER, FLAUM, and KANNE, Circuit Judges.


  • United States Seventh Circuit


  • For Appellees:
  • Anthony J. Rollins (argued), Wagner, Johnston & Rosenthal, P.C., Atlanta, GA, for Plaintiffs-Appellees., Judith A. Hagley, Wendy J. Kisch, Department of Justice Tax Division, Richard Farber (argued), Department of Justice Civil Division, Immigration Litigation, Washington, DC, for Defendant-Appellant.
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