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106 LTD. v. C.I.R.

No. 11-1242.

684 F.3d 84 (2012)

106 LTD., David Palmlund, Tax Matters Partner, Appellant v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided June 22, 2012.

Attorney(s) appearing for the Case

Kyle R. Coleman argued the cause for the appellant.

Patrick J. Urda , Attorney, United States Department of Justice, argued the cause for the appellee. Tamara W. Ashford , Deputy Assistant Attorney General, and Kenneth L. Greene , Attorney, were on brief.

Opinion for the Court filed by Circuit Judge HENDERSON.

KAREN LeCRAFT HENDERSON, Circuit Judge:

106 Ltd. (Partnership), a limited partnership, appearing through its tax matters partner David Palmlund (Palmlund), appeals a decision of the United States Tax Court (Tax Court) upholding the imposition of a forty per cent accuracy-related penalty by the Internal Revenue Service (IRS). See 106 Ltd. v. Comm'r, 136 T.C. 67 (2011). The IRS determined...

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