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RIVER CITY RANCHES # 1 LTD. v. C.I.R.

No. 03-73853.

401 F.3d 1136 (2005)

RIVER CITY RANCHES # 1 LTD., Leon Shepard, Tax Matters Partner, River City Ranches # 2 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 3 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 4 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 5 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 6 Ltd., Leon Shepard, Tax Matters Partner, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed March 25, 2005.

Attorney(s) appearing for the Case

Montgomery W. Cobb, Portland, OR, for the petitioners-appellants.

Eileen J. O'Connor, Assistant Attorney General, Richard Farber, and Anthony T. Sheehan, Department of Justice, Appellate Section, Tax Division, Washington, D.C., for the respondent-appellee.

Before BRIGHT, TASHIMA, and CALLAHAN, Circuit Judges.

BRIGHT, Circuit Judge.

Introduction

We review here an extensive opinion and judgment of the Tax Court1 relating to the tax returns of several affiliated sheep-breeding partnerships. We affirm in part, reverse in part, and remand for further proceedings. The federal Internal Revenue Service ("IRS") issued Final Partnership Administrative Adjustments ("Adjustments") to the tax returns of nine sheep-breeding partnerships for various...

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