United States Ninth Circuit

In a taxpayer's appeal from a tax court's dismissal of his claim for relief from joint and several tax liability with his spouse under 26 U.S.C. section 6015, the order is affirmed where the deficiency challenged by the taxpayer stemmed from a partnership interest that was the subject of an ongoing partnership proceeding under the Tax Equity and Fiscal Responsibility Act and regulated by a separate set of provisions.

Appellate Information

• Decided 01/21/2010
• Published 01/21/2010

Judges

• Before MICHAEL DALY HAWKINS, M. MARGARET McKEOWN, and JAY S. BYBEE, Circuit Judges.

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Cori Flanders-Palmer (argued), Chicoine & Hallert, P.S., Seattle, Washington; John M. Colvin, Chicoine & Hallert, P.S., Seattle, Washington, for the petitioner-appellant.


• For Appellees:
  
• Teresa E. McLaughlin (argued), United States Department of Justice, Tax Division, Washington, D.C.; Randolf L. Hutter, United States Department of Justice, Tax Division, Washington, D.C. for the respondent-appellee.