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United States Ninth Circuit


Sparkman v. Comm'r of Internal Revenue, 06-71476

A decision upholding a notice of deficiency with respect to certain tax years is affirmed over taxpayer's claims that the tax court erred in: 1) finding that one of his business entities lacked economic substance and should be disregarded for income tax purposes; 2) excluding certain amended tax returns from evidence admitted; 3) holding that he had not substantiated several depreciation and charitable deductions; 4) calculating his income for certain years; and 5) imposing accuracy-related penalties under section 6662(a) of the Internal Revenue Code.

Appellate Information

  • Decided 12/10/2007
  • Published 12/10/2007

Judges

  • MILAN D. SMITH, JR., Circuit Judge:, Before:  O'SCANNLAIN, TASHIMA, and MILAN D. SMITH, JR., Circuit Judges.

Court

  • United States Ninth Circuit

Counsel

  • For Appellant:
  • Paul J. Sulla, Jr., Laupahoehoe, HI, for the petitioners-appellants.

  • For Appellees:
  • Eileen J. O'Connor, Assistant Attorney General;  Jonathan S. Cohen, Michelle B. Smalling, United States Department of Justice, Tax Division, Washington, D.C., for the respondent-appellee.
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