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RJT INVESTMENTS X v. C.I.R.

No. 06-3259.

491 F.3d 732 (2007)

RJT INVESTMENTS X; Randall J. Thompson; Tax Matters Partner, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: July 2, 2007.

Attorney(s) appearing for the Case

Counsel who presented argument on behalf of the appellants was Edward M. Robbins, Jr. of Beverly Hills, California.

Counsel who presented argument on behalf of the appellee was Joan L. Oppenheimer of Washington, D.C. Also appearing on the brief were Eileen J. O'Connor, Richard T. Morrison, Gilbert S. Rothenberg, and Richard Farber.

Before WOLLMAN, JOHN R. GIBSON, and MURPHY, Circuit Judges.

WOLLMAN, Circuit Judge.

RJT Investments X, LLC (RJT) and its tax matters partner, Randall Thompson, appeal from the judgement of the United States Tax Court1 sustaining (1) adjustments sought by the Commissioner of the Internal Revenue Service (The "Commissioner" or the "IRS") to RJT's 2001 tax return and (2) the imposition of a penalty for income tax underpayment resulting from gross valuation misstatements and negligence or disregard...

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