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TRANSPAC DRILLING VENTURE 1983-63 v. U.S.

No. 93-5045.

16 F.3d 383 (1994)

TRANSPAC DRILLING VENTURE, 1983-63 by CRESTWOOD HOSPITALS, INC., Transpac Drilling Venture, 1983-1 by Crestwood Hospitals, Inc., Transpac Drilling Venture, 1983-2 by James M. Dobbins, Transpac Drilling Venture, 1983-4 by Bryan D. Burr, Plaintiffs-Appellants, and Transpac Drilling Venture, 1983-14, by Alister Corporation, Transpac Drilling Venture, 1983-38 by Lindsey & Hall, Inc., Plaintiffs, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

February 8, 1994.

Attorney(s) appearing for the Case

Arthur H. Boelter, Boelter & Gale, of Seattle, Washington, argued for plaintiffs-appellants. With him on the brief was John J. White, Jr. and Shawn M. Soderberg.

Sarah K. Knutson, Attorney, Department of Justice, of Washington, D.C., argued for defendant-appellee. With her on the brief were Michael L. Paup, Acting Assistant Attorney General, Gary R. Allen and Teresa E. McLaughlin, Attorneys.

Before NIES, Chief Judge, BENNETT, Senior Circuit Judge, and RADER, Circuit Judge.

NIES, Chief Judge.

In the Internal Revenue Code of 1986 (26 U.S.C. § 11 et seq.), section 6226(b)(3) permits the "tax matters partner" of a limited partnership to file a petition on behalf of the partnership to contest adjustments to partnership income made by the Internal Revenue Service. The appeal in this case, which comes to us from the United States Court of Federal Claims (Margolis, J.), concerns this provision...

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