United States Ninth Circuit

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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


  • Hudson


  • United States Ninth Circuit


  • For Appellant:
  • Steven R. Mather, John A. Dudeck