VAN SCOTEN v. C.I.R.

No. 05-9000.

439 F.3d 1243 (2006)

Ronald F. VAN SCOTEN; Cynthia G. Van Scoten, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent Appellee.

United States Court of Appeals, Tenth Circuit.

March 9, 2006.


Attorney(s) appearing for the Case

Terri A. Merriam (and Wendy S. Pearson, Pearson & Merriam, P.C, with her on the briefs), Seattle, WA, for Petitioners-Appellants.

Anthony T. Sheehan (and Bruce R. Ellisen, Tax Division, Department of Justice, and Eileen J. O'Connor, Assistant Attorney General, on the brief), Washington, D.C., for Respondent-Appellee.

Before KELLY, HENRY, and McCONNELL, Circuit Judges.


PAUL KELLY, JR., Circuit Judge.

Taxpayer-Appellants Ronald and Cynthia Van Scoten (collectively, the "Van Scotens") appeal from the Tax Court's decision in Van Scoten v. Commissioner, T.C. Memo.2004-275, 2004 WL 2785918 (2004) ("T.C.Memo"), holding them liable for an accuracy-related penalty of $2,872 imposed by the Commissioner of Internal Revenue ("Commissioner") as a result of their negligence in claiming losses from a cattle partnership they were...

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