United States Ninth Circuit

A tax court's holding that a husband and wife were liable for deficiencies in their joint income tax returns for certain years, resulting from the husband taking inconsistent positions as to the value of an expensive art collection included in his father's estate, is affirmed where the tax court correctly held that petitioners were bound by the duty of consistency and could not report on their individual tax returns a value different than that stipulated to for an estate tax return.

Appellate Information

• Argued 06/06/2006
• Decided 08/21/2006
• Published 08/21/2006

Judges

• McKEOWN, Circuit Judge., Before STEPHEN REINHARDT, STEPHEN S. TROTT, and M. MARGARET McKEOWN, Circuit Judges.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Steven R. Mather and Elliott H. Kajan, Kajan Mather and Barish, Beverly Hills, CA, for the petitioners.


• For Appellees:
  
• Eileen J. O'Connor, Assistant Attorney General, Jonathan S. Cohen and Francesca U. Tamami, Attorneys, Department of Justice, Tax Division, Washington, D.C., for the respondent.