United States Ninth Circuit
Taproot Administrative Services, Inc. v. Comm'r of Internal Revenue, 10-70892
In a corporation's challenge to a notice of deficiency issued by the IRS, the Tax Court's grant of a motion for summary judgment to the IRS is affirmed, where the corporation was ineligible for S corporation status, and therefore was taxable as a C corporation, because its sole shareholder was a custodial Roth IRA, as ownership of custodial IRAs and Roth IRAs should not be attributed to the underlying individual for purposes of S corporation eligibility.
Appellate Information
- Decided 03/21/2012
- Published 03/21/2012
Judges
- Hudson
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Steven R. Mather, John A. Dudeck