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SNJ LTD. v. C.I.R.

No. 20-70902.

28 F.4th 936 (2022)

SNJ LIMITED; Ritchie N. Stevens; Julie A. Keene-Stevens, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed March 10, 2022.

Attorney(s) appearing for the Case

Fritz Jay Firman (argued), Costa Mesa, California, for Petitioners-Appellants.

Pooja Boisture (argued), Jacob Christensen and Marion E.M. Erickson , Attorneys; David A. Hubbert , Deputy Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellee.

Concurrence by Judge Bataillon.

OPINION

On June 7, 2018, appellants Ritchie N. Stevens and Julie A. Keene-Stevens petitioned the Tax Court for a redetermination of 2006 and 2008 federal income tax deficiencies for the partnership SNJ Limited ("SNJ"). The Tax Court dismissed because appellants failed to petition within 150 days of November 1, 2017...

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