Candyce Martin 1999 Irrevocable Trust v. United States

OPINION

THOMAS, Circuit Judge:

In this appeal, we examine some of the tax consequences arising from the sale of the Chronicle Publishing Company and, specifically, whether the Internal Revenue Service’s proposed adjustment of certain partnership tax items was time barred. Although the ultimate issue is relatively straightforward, both the back story and the legal framework are somewhat complex, requiring us to delve deep in the heart of taxes.

I

The storied Chronicle Publishing Company was founded in the mid-1800s in San Francisco by teenage brothers Charles and M.H. de Young with a borrowed $20…