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HANSEN v. C.I.R.

No. 05-70658.

471 F.3d 1021 (2006)

Gary D. HANSEN; Johnean F. Hansen, Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed December 18, 2006.

Attorney(s) appearing for the Case

Terri A. Merriam, Pearson Merriam, P.C., Seattle, WA, for the petitioner-appellants.

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

Before MARY M. SCHROEDER, Chief Circuit Judge, RICHARD C. TALLMAN and CARLOS T. BEA, Circuit Judges.

BEA, Circuit Judge.

Gary and Johnean Hansen ("Hansens") appeal the judgment of the Tax Court in Hansen v. Commissioner, T.C.M. (RIA) 2004-269 (2004), upholding the Commissioner of Internal Revenue's ("Commissioner") imposition of a negligence penalty pursuant to I.R.C. § 6662(a) for claiming losses in 1991 from a cattle partnership in which they had invested. The Hansens claim error, asserting that the Tax Court ignored relevant facts, applied an improper...

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