Legal Opinion

Bush v. United States

Court of Appeals for the Federal Circuit

Decided May 30, 2013No. 2012-5051PublishedCited by 10 opinions

1Opinion of the Court

NEWMAN, Circuit Judge.

The appellants are nineteen individual taxpayers who were partners of the Denver-based Dillon Oil Technology Partnership in tax years 1983 and 1984. In 2003, after over a decade of litigation, the IRS assessed penalties in accordance with now repealed I.R.C. § 6621(c), which penalizes “substantial” underpayments of tax “attributable to tax motivated transactions” (“TMTs”). The appellants paid the tax and penalties in 2004, and, in 2006, initiated a refund suit in the United States Court of Federal Claims. The court dismissed the appellants’ suit for lack of subject…

2Cases cited16 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Karen S. Reynolds v. Army and Air Force Exchange ServiceCourt of Appeals for the Federal Circuit · 1988
  3. John G. Rocovich, Jr. v. The United StatesCourt of Appeals for the Federal Circuit · 1991
  4. Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
  5. Riehle v. MargoliesSupreme Court of the United States · 1929

11 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. Klamath Irrigation District v. the United States 01-591l and 01-5910l Through 01United States Court of Federal Claims · 2013
  2. Copar Pumice Company, Inc. v. United StatesUnited States Court of Federal Claims · 2013
  3. John Irvine v. United StatesCourt of Appeals for the Fifth Circuit · 2013
  4. McNaughton v. United StatesUnited States Court of Federal Claims · 2014
  5. Skokomish Indian Tribe v. United StatesUnited States Court of Federal Claims · 2014

5 more not listed; retrieve them via the Exa API.

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