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INTERIOR GLASS SYSTEMS, INC. v. U.S.

No. 17-15713.

927 F.3d 1081 (2019)

INTERIOR GLASS SYSTEMS, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed June 26, 2019.

Attorney(s) appearing for the Case

John P. McDonnell (argued), Law Offices of John P. McDonnell, Los Altos, California, for Plaintiff-Appellant.

Teresa E. McLaughlin (argued) and Geoffrey J. Klimas , Attorneys; David A. Hubbert , Acting Assistant Attorney General; Thomas Moore , Assistant United States Attorney; Brian Stretch , United States Attorney; Tax Division, United States Department of Justice, Washington, D.C.; for Defendant-Appellee.

Before: A. Wallace Tashima, Johnnie B. Rawlinson, and Paul J. Watford, Circuit Judges.

OPINION

The Internal Revenue Service (IRS) requires taxpayers to disclose their participation in certain transactions, known as "listed transactions," that the agency has designated for close scrutiny. 26 C.F.R. § 1.6011-4(a), (b)(2); see 26 U.S.C. § 6011(a). To compel compliance with this obligation...

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