United States DC Circuit

In an action contesting the Commissioner of Internal Revenue's proposed adjustments to partnership returns, judgment for the partnership is reversed where the district court did not find that a legitimate, non-tax necessity existed for the formation of the partnership.

Appellate Information

• Argued 11/21/2002
• Decided 01/10/2003
• Published 01/10/2003

Judges

• Before:  SENTELLE, HENDERSON and TATEL, Circuit Judges.

Court

• United States DC Circuit

Counsel

• For Appellant:
  
• Mark V. Holmes, Attorney, U.S. Department of Justice, argued the cause for appellant.   With him on the briefs were Roscoe C. Howard, Jr., U.S. Attorney, Richard Farber and Edward T. Perelmuter, Attorneys, U.S. Department of Justice.


• For Appellees:
  
• Christopher Kliefoth argued the cause for appellees.   With him on the brief were William L. Goldman and Diane L. Cafritz.  Melvin White entered an appearance.