Seaview Trading, LLC, AGK Inve v. CIR

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Case Number:

20-72416

Court:

Appellate - 9th Circuit

Nature of Suit:

  1. March 10, 2023

    Full 9th Circ. Sides With IRS In Partnership's $35.5M Loss Row

    The IRS timely disallowed a partnership's $35.5 million loss as the partnership's failure to strictly comply with filing rules meant the agency's readjustment deadline didn't pass, the full Ninth Circuit ruled Friday, overruling a three-judge panel.

  2. December 13, 2022

    9th Circ. Probes Tax Filings' Validity In $35M Partnership Row

    A Ninth Circuit judge on Tuesday questioned a partnership's arguments that it properly filed its tax returns in a dispute involving a $35.5 million tax shelter-related deduction, saying the partnership relied on IRS guidance lacking the force of law to make its case.

  3. November 14, 2022

    Full 9th Circ. To Review IRS Loss In $35.5M Partnership Row

    The full Ninth Circuit will revisit a panel decision that reversed the U.S. Tax Court in allowing a partnership to claim a $35.5 million tax-shelter-related deduction because the IRS disallowed the claim too late.

  4. July 12, 2022

    9th Circ. Urged To Rethink IRS Loss In $35.5M Partnership Row

    The full Ninth Circuit should review a panel ruling that wrongly permitted a partnership to claim a $35.5 million tax shelter-related deduction, the U.S. government argued, saying the appeals court incorrectly concluded that the IRS disallowed the claim too late.

  5. May 11, 2022

    9th Circ. Reverses IRS Win In $35.5M Partnership Tax Fight

    A split Ninth Circuit panel reversed a U.S. Tax Court decision Wednesday and vacated a $35.5 million tax adjustment the Internal Revenue Service applied to a California-based partnership, ruling the agency's determination was barred by the statute of limitations.

  6. March 05, 2021

    IRS' $35.5M Loss Adjustment Not Time-Barred, 9th Circ. Told

    A partnership's failure to file a tax return for 2001 enabled the IRS to disallow a $35.5 million loss deduction the business claimed for that year roughly a decade later, the U.S. government told the Ninth Circuit on Friday.

  7. January 11, 2021

    IRS' Statute Of Limitations Interpretation Is Harmful, 9th Circ. Told

    The IRS' argument that only narrow circumstances start its time limit for making tax adjustments in a $35.5 million partnership deduction dispute may unduly harm lower-income taxpayers, a taxpayer advocacy group told the Ninth Circuit on Monday.

  8. January 05, 2021

    $35.5M IRS Loss Adjustment Too Late, 9th Circ. Told

    The IRS shouldn't have disallowed a partnership's $35.5 million loss deduction because the statute of limitations on its liability had expired, the partnership told the Ninth Circuit, urging it to reverse a U.S. Tax Court decision.