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HANSEN v. COMMISSIONER OF INTERNAL REVENUE

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, Washington, 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.

Argued and Submitted September 15, 2006 — Seattle, Washington.

Opinion by Judge Bea.

OPINION

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...

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