United States Ninth Circuit

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Twenty-Two Strategic Investment Funds v. US, 15-15551

In an action raising a statute of limitations challenge to the Internal Revenue Service's determination of tax liabilities in a partnership level proceeding under the Tax Equity and Fiscal Responsibility Act, the district court's judgment in favor of the IRS is affirmed where the statute of limitations extensions signed by intervenor were valid, thereby allowing the IRS to issue a Final Partnership Administration Adjustments (FPAA) after the initial limitations period expired but within the extension granted by the consents

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2017/06/07




  • United States Ninth Circuit


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