Legal Opinion
Gary D. Hansen Johnean F. Hansen v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided December 18, 2006No. 05-70658PublishedCited by 52 opinions
1Opinion of the Court
BEA, Circuit Judge.
Gary and Johnean Hansen (“Hansens”) appeal the judgment of the Tax Court in Hansen v. Commissioner, T.C.M. (RIA) 2004-269 (2004), upholding the Commissioner of Internal Revenue’s (“Commissioner”) imposition of a negligence penalty pursuant to I.R.C. § 6662(a) for claiming losses in 1991 from a cattle partnership in which they had invested. The Hansens claim error, asserting that the Tax Court ignored relevant facts, applied an improper negligence standard, and inadequately considered the Hansens’ own victimization as members of the partnership. We have jurisdiction pursuant…
2Cases cited13 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Adams v. JohnsonCourt of Appeals for the Ninth Circuit · 2004
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Kenneth Allen Barbara Allen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1991
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
8 more not listed; retrieve them via the Exa API.
3Cited by52 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
- Evergreen Trading, LLC ex rel. GN Investments, LLC v. United StatesUnited States Court of Federal Claims · 2007
- Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- Calloway v. CommissionerUnited States Tax Court · 2010
47 more not listed; retrieve them via the Exa API.