United States Ninth Circuit
Keller v. Comm'r. of Int'l. Rev., 06-75466
In an appeal from the Tax Court's judgment that the IRS did not abuse its discretion by rejecting Petitioners' offers-in-compromise of their tax liability, the judgment is affirmed in part, where the Commissioner was not obliged by compelling considerations of public policy or equity to accept the offers; but vacated in part, where the Tax Court erred in finding that it lacked jurisdiction to apply interest penalties, because the transactions at issue were tax-motivated.
Appellate Information
- Argued 02/03/2009
- Decided 06/03/2009
- Published 06/03/2009
Judges
- RYMER, Circuit Judge:, Before: B. FLETCHER, PAMELA ANN RYMER and RAYMOND C. FISHER, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Terri A. Merriam, Merriam & Associates, P.C., Seattle, WA, for the petitioners-appellants.
- For Appellees:
- Anthony T. Sheehan, Tax Division, Department of Justice, Washington, DC, for the respondent-appellee.