Legal Opinion
Glenn A. Mortensen v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided February 28, 2006No. 05-1344PublishedCited by 61 opinions
1Opinion of the Court
OPINION
BOYCE F. MARTIN, JR., Circuit Judge.
This is an appeal from the United States Tax Court’s decision upholding the Commissioner’s determination that Mr. Mor-tensen is liable for a section 6662(a) negligence penalty of $784 for the taxable year 1991. The penalty stems from Morten-sen’s deductions on his tax return based on his investment in cattle breeding partnerships established by Walter J. Hoyt III. The Hoyt Partnerships have generated litigation across the country, see e.g., River City Ranches # 1, 85 T.C.M. (CCH) 1365, 1371, 2003 WL 21205284, and culminated in Mr. Hoyt’s fraud…
2Cases cited15 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- United States v. BoyleSupreme Court of the United States · 1985
- Adams v. JohnsonCourt of Appeals for the Ninth Circuit · 2004
- Freytag v. CommissionerUnited States Tax Court · 1987
- Rybak v. CommissionerUnited States Tax Court · 1988
10 more not listed; retrieve them via the Exa API.
3Cited by61 opinions
- Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Gary D. Hansen Johnean F. Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- 106 Ltd. v. Commissioner, IRSCourt of Appeals for the D.C. Circuit · 2012
56 more not listed; retrieve them via the Exa API.