United States Ninth Circuit
Hansen v. Comm'r of Internal Revenue, 05-70658
A tax court's judgment upholding the imposition of a negligence penalty pursuant to I.R.C. section 6662(a) on petitioners-taxpayers for claiming losses in 1991 from a cattle partnership in which they had invested is affirmed where: 1) in light of the numerous warning signals brought home to petitioners regarding their investment in a fraudulent partnership, they failed to show the tax court clearly erred in upholding the negligence penalty; 2) a prior decision did not justify petitioners' actions; and 3) petitioners' victimization did not preclude a finding of negligence.
Appellate Information
- Decided 12/18/2006
- Published 12/18/2006
Judges
- BEA, Circuit Judge., Before MARY M. SCHROEDER, Chief Circuit Judge, RICHARD C. TALLMAN and CARLOS T. BEA, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Terri A. Merriam, Pearson Merriam, P.C., Seattle, WA, for the petitioner-appellants.
- For Appellees:
- Eileen J. O'Connor, Assistant Attorney General, Richard Farber, Anthony T. Sheehan, Attorneys, Tax Division, U.S. Department of Justice, Washington D.C., for the respondent-appellee.