Legal Opinion
Meruelo v. Commissioner
Court of Appeals for the Ninth Circuit
Decided August 16, 2012No. 11-70015PublishedCited by 24 opinions
1Opinion of the Court
OPINION
N.R. SMITH, Circuit Judge:
The Internal Revenue Service (IRS) validly issues a Notice of Deficiency (“NOD”) to a partner in a partnership, when (1) no partnership-level proceeding is pending, (2) no notice of final partnership administrative adjustment (“FPAA”) has been issued, and (3) the normal three-year statute of limitations in 26 U.S.C. § 6229(a) 1 has not expired. As such, we affirm the Tax Court’s denial of Alex and Liset Meruelo’s (husband and wife and hereinafter re ferred to as the Meruelos or the petitioners) motion to dismiss for lack of jurisdiction.
I. BACKGROUND
A. Facts
Mr.…
2Cases cited17 opinions
- United States v. HinksonCourt of Appeals for the Ninth Circuit · 2009
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- GAF Corp. v. CommissionerUnited States Tax Court · 2000
- Dudley B. Merkel Ladonna K. Merkel David A. Hepburn, and Nancy J. Hepburn v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
12 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Candyce Martin 1999 Irrevocable Trust v. United StatesCourt of Appeals for the Ninth Circuit · 2014
- Organic Cannabis Foundation v. CirCourt of Appeals for the Ninth Circuit · 2020
- Maines v. Comm'rUnited States Tax Court · 2015
- Shea Homes, Inc. & Subsidiaries v. CommissionerCourt of Appeals for the Ninth Circuit · 2016
- John Bedrosian v. CirCourt of Appeals for the Ninth Circuit · 2019
19 more not listed; retrieve them via the Exa API.