United States Eighth Circuit

A judgment sustaining adjustments sought by the IRS to appellant's 2001 tax return and the imposition of a penalty for income tax underpayment resulting from gross valuation misstatements and negligence or disregard of rules and regulations is affirmed where a tax court properly found that as a partnership item appellant was a sham which was formed for the purpose of tax avoidance.

Appellate Information

• Decided 07/02/2007
• Published 07/02/2007

Judges

• WOLLMAN, Circuit Judge., Before WOLLMAN, JOHN R. GIBSON, and MURPHY, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Counsel who presented argument on behalf of the appellants was Edward M. Robbins, Jr. of Beverly Hills, California.


• For Appellees:
  
• Counsel who presented argument on behalf of the appellee was Joan L. Oppenheimer of Washington, D.C. Also appearing on the brief were Eileen J. O'Connor, Richard T. Morrison, Gilbert S. Rothenberg, and Richard Farber.