NPR Investments, L.L.C. Ex Rel. Roach v. United States

PRISCILLA R. OWEN, Circuit Judge:

In a Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) 1 partnership proceeding, the district court held that valuation misstatement and substantial understatement tax penalties were inapplicable to NPR Investments, LLC (NPR). The United States appeals those determinations. The district court also held that a notice of a Final Partnership Administrative Adjustment (FPAA) issued by the Internal Revenue Service (IRS) to NPR, which made adjustments to NPR’s tax return and could result in additional tax liabilities to some of the partners, was valid. NPR,…