Legal Opinion
Lincir v. Commissioner
Court of Appeals for the Ninth Circuit
Decided February 22, 2002No. 01-70018; IRS No. 22934-89PublishedCited by 11 opinions
1Opinion of the Court
MEMORANDUM *
Tom and Diane Lincir appeal the tax court’s decision upholding the IRS’s assessment of negligence penalties under 26 *280U.S.C. § 6653(a)1 and increased interest under 26 U.S.C. § 6621(c). They also appeal the tax court’s determination that it lacked jurisdiction to hear their claim that the IRS should use its new interest-netting rule when calculating the penalties and increased interest. We have jurisdiction to hear this appeal pursuant to 26 U.S.C. § 7482, and we affirm.
I. Negligence Penalties and Increased Interest
The tax court did not clearly err when it held that the Lincirs…
2Cases cited13 opinions
- Whitman v. American Trucking Assns., Inc.Supreme Court of the United States · 2001
- Department of Commerce v. United States House of RepresentativesSupreme Court of the United States · 1999
- Leo Goldman and Pauline Goldman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- David G. Collins Pamela Collins Bernie Gates Maureen Gates Anne Hamsley and David Dister v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Freedom to Travel Campaign v. NewcombCourt of Appeals for the Ninth Circuit · 1996
8 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Estate of Smith v. Comm'rUnited States Tax Court · 2004
- Rogers v. Comm'rUnited States Tax Court · 2005
- Abrahamsen v. Comm'rUnited States Tax Court · 2014
- Lincir v. Comm'rUnited States Tax Court · 2007
- Abrahamsen v. Comm'rUnited States Tax Court · 2014
6 more not listed; retrieve them via the Exa API.