United States Ninth Circuit
Hongsermeier v. Comm'r of Internal Rev., 07-72828
The tax court's determination of petitioners' federal income tax deficiencies and liability for underpayment of interest is affirmed where: 1) the tax court's determination of the percentage deduction in the taxpayers' deficiencies, plus other benefits, accorded with the court's mandate in Dixon and was not an abuse of discretion; 2) the IRS Commissioner's position did not constitute fraud on the court or bad faith; and 3) the Tax Court did not abuse its discretion in relying on the materials available to determine a settlement fraction.
Appellate Information
- Decided 09/01/2010
- Published 09/01/2010
Judges
- Richard R. Clifton
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Michael Louis Minns, Nathan J. Hochman