United States Ninth Circuit

Because the Tax Court did not sufficiently articulate the basis for its valuation of an estate's omitted assets, its upholding of an IRS deficiency ruling and imposition of a 75% penalty for fraud were reversed.

Appellate Information

• Decided 01/30/2002
• Published 01/30/2002

Judges

• McKEOWN, Circuit Judge., Before FERNANDEZ, KLEINFELD, and McKEOWN, Circuit Judges.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Avram Salkin (argued), Hochman, Salkin, Rettig, Toscher & Perez, P.C., Beverly Hills, CA;  Robert A. Levinson, Levinson & Kaplan, Encino, CA, for petitioners-appellants.


• For Appellees:
  
• Randolph L. Hutter, Department of Justice, Tax Division, Washington, DC, for respondent-appellee.