Legal Opinion

Abelein v. United States

Court of Appeals for the Ninth Circuit

Decided March 27, 2003No. 02-35054PublishedCited by 9 opinions

1Opinion of the Court

OPINION

FERNANDEZ, Circuit Judge.

After the Internal Revenue Service audited the comings, goings and machinations involving cattle and sheep breeding tax shelter partnerships organized by Walter J. Hoyt III, it sent out Notices of Final Partnership Administrative Adjustment (FPAA) forms to Daniel Abelein and other investors whom it considered to be partners. Abelein and numerous other investors (hereafter collectively Abelein) then brought this action against the United States on the basis that their confidential tax return information had been improperly disclosed. See 26 U.S.C. § 7431(a)(1).…

2Cases cited11 opinions

  1. Gary E. Wallis, Husband Carol Wallis, Wife v. J.R. Simplot CompanyCourt of Appeals for the Ninth Circuit · 1994
  2. Hector Montero-Martinez Gregorio Pedro Montero-Hernandez v. John Ashcroft, Attorney General of the United StatesCourt of Appeals for the Ninth Circuit · 2002
  3. Commissioner v. LundySupreme Court of the United States · 1996
  4. Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
  5. Larry D. Delpit Dorothy D. Delpit v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994

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3Cited by9 opinions

  1. Ian Michael Stead Belinda A. Stead v. United StatesCourt of Appeals for the Ninth Circuit · 2005
  2. Abelein v. United StatesCourt of Appeals for the Ninth Circuit · 2003
  3. Emerging Money Corp. v. United StatesDistrict Court, D. Connecticut · 2012
  4. At & T Communications of California Inc., a California Corporation, and MCI Worldcom Network Services, Inc., a Delaware Corporation MCI Metro Access Transmission Services, Llc, a Delaware Corporation v. Pacific Bell Telephone Company, a California Corporation Public Utilities Commission of the State of California Loretta M. Lynch Henry M. Duque Richard A. Bilas Carl W. Wood Geoffrey F. Brown, in Their Official Capacities as Commissioners of the Public Utilities Commission of the State of California, Not as Individuals, at & T Communications of California Inc., a California Corporation, and MCI Worldcom Network Services, Inc., a Delaware Corporation MCI Metro Access Transmission Services, Llc, a Delaware Corporation v. Pacific Bell Telephone Company, a California Corporation Public Utilities Commission of the State of California Loretta M. Lynch Henry M. Duque Richard A. Bilas Carl W. Wood Geoffrey F. Brown, in Their Official Capacities as Commissioners of the Public Utilities Commission of the State of California, Not as Individuals, at & T Communications of California Inc., a California Corporation MCI Worldcom Network Services, Inc., a Delaware Corporation MCI Metro Access Transmission Services, Llc, a Delaware Corporation v. Pacific Bell Telephone Company, a California Corporation, Public Utilities Commission of the State of California Loretta M. Lynch Henry M. Duque Richard A. Bilas Carl W. Wood Geoffrey F. Brown, in Their Official Capacities as Commissioners of the Public Utilities Commission of the State of California, Not as IndividualsCourt of Appeals for the Ninth Circuit · 2004
  5. Barone v. Comm'rUnited States Tax Court · 2012

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