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WALTHALL v. U.S.

Nos. 96-35237, 96-35271 and 96-35830.

131 F.3d 1289 (1997)

Robert WALTHALL; Dorothy Walthall; Jerry T. Dennis, Plaintiffs, and David Raihl; June Raihl, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee. John CAMACHO; Barbara Camacho, Plaintiffs-Appellants, and Robert Walthall; Dorothy Walthall; Jerry T. Dennis, Plaintiffs, v. UNITED STATES of America, Defendant-Appellee. Robert WALTHALL; Dorothy Walthall, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided November 19, 1997.

Attorney(s) appearing for the Case

Erik LeRoy, Anchorage, AK, for plaintiffs-appellants Raihls.

George R. Lyle, Guess & Rudd, Anchorage, AK, for plaintiffs-appellants Camachos.

Charles F. Schuetze, Davis & Davis, John L. Hoffer, Jr., Anchorage, AK, for plaintiffs-appellants Walthalls.

Pamela C. Berry, Tax Division, United States Department of Justice, Washington, DC, for defendant-appellee.

Before: WALLACE, JOHN T. NOONAN, Jr., and THOMPSON, Circuit Judges.

Opinion by Judge WALLACE; Partial Concurrence and Partial Dissent by Judge NOONAN.

WALLACE, Circuit Judge:

In these consolidated appeals, we consider whether the Tax Equity and Fiscal Responsibility Act of 1982 (Act) provides constitutionally adequate notice to indirect partners of multi-tiered partnerships, and if so, whether the Internal Revenue Service (IRS) complied with the requirements of the statute.

I

In 1983, the Walthalls, Camachos...

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