United States Ninth Circuit
Martin 1999 Irrevocable Trust v. US, 11-17879
The district court's denial of a petition for readjustment of partnership items, brought by plaintiffs, a group of heirs of the founders of Chronicle Publishing Company, in connection with its sale and resulting tax consequences, is: 1) affirmed in part, where the extension agreements between plaintiffs and the IRS encompass some of the adjustments made to 2000-A by the IRS's 2000-A Notice of Final Partnership Administrative Adjustment (FPAA), and the FPAA to 2000-A extended the limitations period for assessing tax beyond the extension agreements and through the present litigation; and 2) reversed in part, where the agreements do not extend to adjustments in the 2000-A FPAA that are not directly attributable to the First Ship partnership.
Appellate Information
- Decided 01/13/2014
- Published 01/13/2014
Judges
- THOMAS
Court
- United States Ninth Circuit