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BEDROSIAN v. C.I.R.

No. 18-70066.

940 F.3d 467 (2019)

John C. BEDROSIAN; Judith D. Bedrosian, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed October 8, 2019.

Attorney(s) appearing for the Case

Steve R. Mather (argued), Mather Turanchik Law Corp., Los Angeles, California; Richard E. Hodge , Malibu, California; for Petitioners-Appellants.

Deborah K. Snyder (argued), Gilbert S. Rothenberg , and Andrew M. Weiner , Attorneys; Travis A. Greaves , Deputy Assistant Attorney General; Richard E. Zuckerman , Principal Deputy Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellee.

Before: Mary M. Schroeder and Susan P. Graber, Circuit Judges, and Joan H. Lefkow, District Judge.

OPINION

Taxpayers John and Judith Bedrosian seek to challenge the Internal Revenue Service's (IRS's) disallowance of deductions that they claimed on their 1999 and 2000 returns. Because the deductions were generated by a partnership entity, the IRS initiated a partnership proceeding that resulted in administrative...

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