SEAVIEW TRADING, LLC v. COMM'R OF INTERNAL REVENUE

No. 20-72416.

34 F.4th 666 (2022)

SEAVIEW TRADING, LLC, AGK Investments, LLC, Tax Matters Partner, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed May 11, 2022.


Attorney(s) appearing for the Case

Lisa S. Blatt (argued), Sarah M. Harris , J. Matthew Rice , and Kimberly Broecker , Williams & Connolly LLP, Washington, D.C.; David W. Foster and Armando Gomez , Skadden Arps Slate Meagher & Flom LLP, Washington, D.C.; for Petitioner-Appellant.

Anthony T. Sheehan (argued) and Arthur T. Catterall , Attorneys; David A. Hubbert , Acting Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellee.

Professor T. Keith Fogg , Director; Janice Rovner Feldman , Volunteer Attorney; Tax Clinic at the Legal Services Center of Harvard Law School, Jamaica Plain, Massachusetts; for Amici Curiae Center for Taxpayer Rights and Federal Tax Clinic at the Legal Services Center of Harvard Law School.

Dissent by Judge Bade.


OPINION

Imagine you get a letter from an Internal Revenue Service official saying that the IRS never received the tax return you thought you filed four years ago. In response, you fax a copy of your return to the IRS official. Two years go by, you then talk with an...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases