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UTAM, LTD. v. C.I.R.

No. 10-1262.

645 F.3d 415 (2011)

UTAM, LTD. and DDM Management, Inc., Tax Matters Partner, Appellees v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellant.

United States Court of Appeals, District of Columbia Circuit.

Decided June 21, 2011.

Attorney(s) appearing for the Case

Gilbert S. Rothenberg , Deputy Assistant Attorney General, U.S. Department of Justice, argued the cause for appellant. With him on the briefs were Michael J. Haungs and Joan I. Oppenheimer , Attorneys.

James F. Martens argued the cause for appellees. With him on the brief were Michael B. Seay , Amanda Traphagan , and Renea Hicks .

Roger J. Jones , Andrew R. Roberson and Kim Marie Boylan , were on the brief for amicus curiae Bausch & Lomb Incorporated in support of appellees.

Opinion for the Court filed by Senior Circuit Judge RANDOLPH.

RANDOLPH, Senior Circuit Judge:

This appeal presents two broad issues. The first is whether an understatement of income can trigger the six-year, extended tax assessment period under § 6501(e)(i)(A) of the Internal Revenue Code (26 U.S.C.) when the understatement results from an overstatement of basis in sold property. The second is whether the mailing of a notice of final partnership administrative adjustment by the IRS tolls an individual partner's limitation...

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