KEENE-STEVENS v. C.I.R.

No. 21-71082.

72 F.4th 1015 (2023)

Julie A. KEENE-STEVENS; Ritchie N. Stevens, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Argued and Submitted April 10, 2023 San Francisco, California.


Attorney(s) appearing for the Case

Jacob E. Christensen (argued) and Francesco Ugolini , Attorneys, Tax Division; David A. Hubbert , Deputy Assistant Attorney General; United States Department of Justice; Washington, D.C.; William J. Wilkins , Chief Counsel; Internal Revenue Service; Washington, D.C.; for Respondent-Appellant.

A. Lavar Taylor (argued), Taylor Nelson Amitrano LLP, Santa Ana, California; Fritz Firman , Weber Firman, Costa Mesa, California; for Petitioners-Appellees.

Before: Richard A. Paez, Richard R. Clifton, and Holly A. Thomas, Circuit Judges.


OPINION

This dispute arises from the Tax Court's determination that Ritchie N. Stevens and Julie A. Keene-Stevens (Taxpayers)1 owed neither deficiencies nor penalties for taxable years 2007 and 2009 through 2012 as a result of large, alleged partnership losses. We must decide first whether...

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