Legal Opinion

Charles G. Fargo Elizabeth A. Fargo v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided May 8, 2006No. 04-72190PublishedCited by 85 opinions

1Opinion of the Court

HALL, Senior Circuit Judge.

Charles and Elizabeth Fargo (Taxpayers) appeal the decision of the Tax Court holding that the Commissioner of Internal Revenue did not abuse his discretion by rejecting their offer to pay $7,500 in compromise of the approximately $104,000 interest owed on their 1983 and 1984 federal income tax liabilities. We affirm.

I. Facts

More than twenty years ago, Taxpayers bought interests in two partnerships: the Jackson & Associates Partnership (Jackson), and the Smith & Asher Associates Partnership (Smith & Asher). In 1983, Taxpayers claimed a loss of $30,767 attributable to…

2Cases cited16 opinions

  1. United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
  2. Cooter & Gell v. Hartmarx Corp.Supreme Court of the United States · 1990
  3. Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
  4. United States v. JamesSupreme Court of the United States · 1986
  5. United States v. Gloria Ann MoralesCourt of Appeals for the Ninth Circuit · 1997

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

3Cited by85 opinions

  1. Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006
  2. Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
  3. Thompson v. CommissionerUnited States Tax Court · 2013
  4. Wadleigh v. CommissionerUnited States Tax Court · 2010
  5. Johnson v. CommissionerUnited States Tax Court · 2011

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

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