United States Federal Circuit

The "principal place of business" provision of 26 U.S.C. section 6226(a)(2) of the Internal Revenue Code does not impose an additional jurisdictional requirement on persons wishing to challenge final partnership administrative adjustments since section 6226 is a venue provision.

Appellate Information

• Decided 02/16/2005
• Published 02/16/2005

Judges

• RADER, Circuit Judge., Before RADER, LINN, and DYK, Circuit Judges.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Renee F. McElhaney, Cox Smith Matthews Incorporated, of San Antonio, Texas, argued for petitioners-appellants.   With her on the brief were Matthew S. Parkin and Ellen B. Mitchell.   Of counsel on the brief were William R. Cousins III and M. Todd Welty, Meadows, Owens, Collier, Reed, Cousins & Blau, L.L.P. of Dallas, Texas.


• For Appellees:
  
• Richard T. Morrison, Tax Division, United States Department of Justice, of Washington, DC, argued for respondent-appellee.   On the brief were Eileen J. O'Connor, Assistant Attorney General, David I. Pincus and Francesca Ugolini, attorneys.