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CURR-SPEC PARTNERS, L.P. v. C.I.R.

No. 08-60815.

579 F.3d 391 (2009)

CURR-SPEC PARTNERS, L.P., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

August 11, 2009.

Attorney(s) appearing for the Case

J. Winston Krause (argued), Krause & Associates, LP, Susan Schlesinger Vance (argued), Alexander Dubose & Townsend, LLP, Austin, TX, for Petitioner-Appellant.

Karen G. Gregory, U.S. Dept. of Justice, Robert R. Di Trolio, U.S. Tax Court, Michael J. Haungs (argued), Joan I. Oppenheimer, Nathan J. Hochman, U.S. Dept. of Justice, Tax Div. Appellate Section, Clarissa C. Potter, I.R.S., Washington, DC, for Respondent-Appellee.

Before REAVLEY, WIENER, and SOUTHWICK, Circuit Judges.

WIENER, Circuit Judge:

Petitioner-Appellant Curr-Spec Partners, L.P. ("Curr-Spec"), asks us to interpret the interplay between the limitation provisions of Internal Revenue Code ("IRC") § 6229(a) and IRC § 6501(a). Specifically, we are asked to determine whether IRC § 6229(a) provides an independent limitations period for Respondent-Appellee Commissioner of Internal Revenue's (the "Commissioner's") issuance...

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