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 In 2003, after over a decade of litigation, the IRS assessed penalties in accordance with now repealed I.R.C. § 6621(c), which penalizes “substantial” underpayments of tax “attributable to tax motivated transactions” (“TMTs”).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
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Karen S. Reynolds v. Army and Air Force Exchange ServiceCourt of Appeals for the Federal Circuit · 1988
- John G. Rocovich, Jr. v. The United StatesCourt of Appeals for the Federal Circuit · 1991
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Riehle v. MargoliesSupreme Court of the United States · 1929
11 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Klamath Irrigation District v. the United States 01-591l and 01-5910l Through 01United States Court of Federal Claims · 2013
- Copar Pumice Company, Inc. v. United StatesUnited States Court of Federal Claims · 2013
- John Irvine v. United StatesCourt of Appeals for the Fifth Circuit · 2013
- McNaughton v. United StatesUnited States Court of Federal Claims · 2014
- Skokomish Indian Tribe v. United StatesUnited States Court of Federal Claims · 2014
5 more not listed; retrieve them via the Exa API.