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TWENTY-TWO STRATEGIC INV. FUNDS v. U.S.

No. 15-15551.

859 F.3d 684 (2017)

TWENTY-TWO STRATEGIC INVESTMENT FUNDS, Petitioner, and Birch Ventures, LLC; Tom Gonzales, Intervenors-Appellants, v. UNITED STATES of America, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed June 7, 2017.

Attorney(s) appearing for the Case

Mark Wray (argued), Law Offices of Mark Wray, Reno, Nevada, for Intervenors-Appellants.

Andrew M. Weiner (argued) and Thomas J. Clark , Attorneys; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellee.

Before: Sidney R. Thomas, Chief Judge, Kim McLane Wardlaw, Circuit Judge, and Cathy Ann Bencivengo, District Judge.

OPINION

We consider in this case whether consents to extend the statute of limitations for the assessment of tax attributable to a partnership item, signed by the taxpayer-partner, are invalid because of a third party's alleged conflict of interest or duress. Under the circumstances...

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