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MILENBACH v. C.I.R.

No. 97-70123.

318 F.3d 924 (2003)

Sheldon R. MILENBACH; Phyllis Milenbach, et al.; Los Angeles Raiders, a California Limited Partnership, Allen Davis, Tax Matters Partner; Los Angeles Raiders, a California Limited Partnership, A.D. Football, Inc., Tax Matters Partner, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed February 6, 2003.

Attorney(s) appearing for the Case

Jerome B. Falk, Jr., Stuart S. Lipton, Douglas A. Winthrop, Clara J. Shin, Howard, Rice, Nemerovski, Canady, Falk & Rabkin, A Professional Corporation, San Francisco, CA, for the petitioners-appellants.

Kenneth W. Rosenberg, Department of Justice, Tax Division, Washington, D.C., for the respondent-appellee.

Before: TASHIMA, THOMAS, and PAEZ, Circuit Judges.

TASHIMA, Circuit Judge.

The Commissioner of Internal Revenue determined deficiencies in Petitioners-Appellants Sheldon and Phyllis Milenbach's federal income taxes for the years 1980 through 1982. The Commissioner also issued notices of Final Partnership Administrative Adjustments determining adjustments to the income of the Los Angeles Raiders, a California Limited Partnership, for the years 1983 through 1989. Petitioners (collectively the "Raiders") appeal from...

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